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 licenses do you need to sell alcohol online direct to consumers in the UK?
The licensing requirements for online alcohol sales are complex and interpretation varies by local authority, so it's essential to speak directly with your local licensing team and HMRC. **Key points members have confirmed:** - **Premises license** — Required if you're selling alcohol online from your own premises (e.g. office or home). If you're using a warehouse or distribution partner with their own premises license, you may not need one yourself, but this is a grey area open to local interpretation. Some local authorities insist you need a 24-hour premises license for round-the-clock online sales; others take a different view. The premises license is typically tied to where payment is taken (your website), not where stock is held. - **Personal license** — Conflicting advice here. HMRC told one member you don't need a personal license for D2C online sales (the Wine & Spirits Trade Association confirmed this). However, others report being told by HMRC that a personal license *is* required for online sales and events. This appears to vary by region and HMRC officer interpretation. - **AWRS (Alcohol Wholesale Registration Scheme)** — One member clarified this is for selling to the trade only, not D2C. - **Age verification** — If you hold a premises license, age verification on your website (e.g. the "are you 18?" check) counts as your side of age verification; the delivery company is then responsible for checking age on receipt. **Recommended approach:** - Speak directly to **HMRC** and your local licensing authority before launch — don't rely on online information or other businesses' experiences, as interpretation varies significantly by area (e.g. Brighton and London have reportedly different requirements). - The **Wine & Spirits Trade Association (WSTA)** was recommended by members as a reliable source of guidance. - If using a warehouse or third-party distributor, confirm they hold their own premises license. **Caveat:** Members reported significant confusion and conflicting information across the industry. Local authority interpretation appears to be the deciding factor.
What alcohol licenses are required to sell online direct-to-consumer and B2B in the UK?
You need multiple licenses depending on your sales channel: **B2B sales:** Members confirm you must register with **AWRS (Alcohol Wholesaler Registration Scheme)** via the HMRC website (https://www.gov.uk/guidance/the-alcohol-wholesaler-registration-scheme-awrs). This is the legal requirement for wholesaling alcohol to other businesses. **D2C online sales:** You can sell online without additional restrictions, but the goods must ship from a licensed premises. This can be your own premises or a third-party fulfilment house that holds an alcohol license. **Required premises and personal licenses:** For any D2C operation, you need: - An **off-licence for your premises** (the physical location from which alcohol is shipped) - A **personal licence for the Designated Premises Supervisor (DPS)**—the individual responsible for the premises Members emphasize that the structure is: AWRS registration for B2B wholesale eligibility, plus premises and personal licensing for the actual location where stock is held and shipped. If using a third-party fulfilment house, that house must already hold the necessary alcohol premises license.
How can drinks brands get listed on Amazon without their own premises license?
Getting on Amazon without a personal premises license is difficult but members have found a few workarounds—though none are straightforward. **Key approaches members have used:** - **Get a premises license in your own name** — One member resolved Amazon's rejection of their LCB storage license by applying for a premises license at their flat in their personal name rather than their Ltd Co, and Amazon eventually accepted it. They noted this required convincing the local council (in their case Lambeth) of the business case. - **Use a fulfilment/agency partner** — Members recommend **Rosetta Brands**, which handles Amazon compliance and fulfillment for brands; they offer tiered packages depending on SKU count and marketing spend. At least one member hired an agency to handle the Amazon application but they gave up after 2 months. Other members mention working with agencies but note it's "pay to play" and have shelved the idea as a result. Some members have been offered introductions to other "great" fulfilment companies via direct message that can handle this, though details remain confidential within the group. - **Try persistence and escalation** — One member reported success by resubmitting their application entirely in capital letters and getting approved; another noted that back in 2020, repeated escalation requests to a manager eventually worked. **Important caveats:** - Amazon's acceptance criteria are opaque and inconsistent. Multiple members have had applications rejected despite having valid premises and personal licenses in the correct name, and Amazon has refused to explain why. - Amazon's support is largely automated; you need to be doing £250k+ annually before a human account manager will engage with you. - Several members report their account managers have stopped responding to emails and describe the whole process as "frustrating" and "impossible to speak to anyone." - Even with premises licenses, some members' applications were rejected without clear explanation.
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.
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 are the new UK alcohol duty bands, rates, and effective implementation dates under the duty reform?
The UK government has radically restructured alcohol duty to tax all products in proportion to their alcohol content. The system moves from 15 duty bands to 6 standardised bands across all product categories. **New duty bands:** - 1.2–3.4% ABV (reduced rate to encourage low-strength innovation) - 3.5–8.4% ABV - 8.5–22% ABV - Above 22% ABV Above 8.5% ABV, all products (beer, wine, cider, spirits, etc.) pay the same rate of duty based on alcohol content, removing category-specific advantages. **Key reliefs and incentives:** - **Reduced rates for products below 3.5% ABV** — designed to encourage manufacturers to develop lower-alcohol options - **Small producer relief** — applies to smaller producers of wine, cider, spirits, and made-wine below 8.5% ABV - **Draft relief** — duty rates on draft beer and cider cut by 5% to support pubs and responsible drinking **Implementation:** Effective from February 2022 (note: one member initially stated 2023, but the corrections confirm 2022). The government consulted on detailed regulations with a closure date of 30 January 2022. **Expected market impact:** Members noted that spirits duty will increase, while ciders, sparkling wines, and beer will generally see lower duty. English sparkling wine is expected to benefit significantly. Members warned to consider price positioning ahead of implementation, as regulations may shift during the consultation period. **Northern Ireland caveat:** Northern Ireland may face different duty bands or rates depending on EU negotiations during the consultation period, so the framework may not apply uniformly across the UK.
What is the B Corp certification process for drinks brands, particularly regarding articles of association changes and revenue reporting for resubmission?
B Corp certification in the community has a dedicated sub-group. Several members have recently completed the process. **Articles of association changes:** Multiple members have completed this step; connect via the dedicated B Corp member group for detailed guidance on requirements. **Revenue reporting for resubmission:** When resubmitting to B Corp, you may encounter a system limitation that only allows submission of a single revenue figure (rather than separate gross and net), with certification points calculated as a percentage of that number. - **Gross revenue (including duty) is the standard submission.** Members who have completed resubmissions report that B Corp expects gross revenue including duty, not ex-duty net revenue. This aligns with industry standard practice for drinks brands. - **Both gross and net should be tracked internally**, even if only one can be submitted to the system. Members track both figures for their own compliance and donation calculations. - **For points-based metrics (e.g. charity donations as % of revenue):** Members calculate these against gross revenue including duty, which is what they submit to B Corp. Members recommend connecting with the private B Corp founder group (link available from community moderators) for real-time support, as several founders are actively navigating resubmissions and can offer current guidance on system quirks and B Corp's latest expectations.
What are the key regulations and compliance requirements for selling alcohol via e-commerce in the USA, and what solutions exist to navigate the three-tier system?
US alcohol e-commerce is heavily regulated by state laws and the three-tier system, making direct-to-consumer sales significantly more complex and expensive than in the UK. However, it is possible with the right partners. **Available solutions and fulfillment partners:** - **HeyTipple** — offers e-commerce fulfillment specifically designed to navigate the three-tier system; they currently operate or will soon operate in the USA and are worth a direct call to discuss their service model - **Bottle Nexus** — provides fulfillment services but does not handle imports - **Reserve Bar** — provides fulfillment services but does not handle imports **Key considerations:** - The three-tier system (distributor → wholesaler → retailer requirements) adds significant complexity and cost to operations - US margins are considerably tighter than the UK, making profitability challenging in the short term - Direct Amazon sales is not a viable route due to their non-participation in alcohol e-commerce - Having a business partner with established US alcohol industry connections (e.g., wine production experience in regions like Napa Valley) can be invaluable for navigating state-specific regulations **Advice:** Members recommend treating US e-commerce as a medium- to long-term play rather than a quick revenue opportunity. Connecting with experienced partners who have navigated the three-tier system is essential before launching.
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.
Should case barcodes be the same as bottle barcodes, or should they be unique?
Case barcodes should be **completely different from bottle barcodes**. Members consistently recommend using unique codes because cases and bottles are different stock-keeping units (SKUs). This becomes critical if you move into wholesale accounts like Booker or Costco that sell full cases alongside individual bottles—using the same barcode could result in customers being charged a bottle price for a full case, creating serious errors in point-of-sale systems. For any barcode queries or registration, members recommend **contacting GS1 directly** for guidance on proper barcode assignment.
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.
What online training courses and providers should I use to prepare for and obtain a personal license from a local authority?
You'll need to complete a course (not just an exam) to get a certificate before applying for your personal license with your local authority. Members recommend the following providers: - **BTBL** (https://www.btbl.co.uk/alcohol_licensing) — Peter runs this and members found him helpful, with links and resources available on the site - **CPL Training** (https://www.cpltraining.co.uk/) — used by members with positive feedback - **Hospitality Training Solutions** (https://hospitalitytrainingsolutions.co.uk/product/personal-licence-courses/) — completed by members and rated well The process is straightforward; members noted "You'll be fine" with these established training routes.
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.
What is the APPA registration process, how long does it take, and what are the reporting and warehousing requirements?
APPA registration is currently backlogged, with members reporting 2+ week delays on ID issuance. Once registered, the process itself is straightforward. **Registration and timeline:** - Expect delays; members have waited 2+ weeks for their APPA ID after application - APPA staff are reportedly "snowed under" working through the backlog **Reporting requirements:** - Members can continue submitting **W1 and W5 forms** while awaiting APPA approval - Once your APPA number is active, you can file **nil returns** instead of W1 and W5 forms - Members have successfully submitted nil returns; the process is described as "easy and straightforward" **Warehousing considerations:** - **Do not close your TF (Trade and Excise) license or warehouse yet** — several members flagged that APPA numbers do not yet work with EMCS (Excise Movement and Control System) - You will likely still need your existing warehousing and TF license to use EMCS, even after obtaining your APPA number - If you've asked the NRU (National Receipts Unit) to close your warehouse, follow up to reverse the request or delay closure until EMCS compatibility is clarified **Caveats:** The integration between APPA and EMCS is still in flux; do not assume you can decommission legacy systems immediately upon APPA approval.
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.
What are the SALSA accreditation requirements for drinks businesses and when is it mandatory?
SALSA accreditation is increasingly required by larger retailers and wholesalers for drinks listings, particularly for RFP (request for proposal) processes with major stockists. Here's what members found: **When it's needed:** - Large grocery retailers typically require proof of SALSA for listing approval - Smaller, local wholesalers may not mandate it, but larger ones do - Essential if you're producing spirits or other drinks for third-party clients **Two routes depending on your production setup:** - **Outsourced production** — If you use a contract manufacturer (co-packer) for blending and canning, their existing SALSA certification usually covers you; you won't need your own certification - **In-house production** — Getting SALSA approved yourself is "reasonably onerous" and involves significant paperwork and process documentation **What to expect:** - Substantial paperwork and administrative burden to achieve and maintain certification - Annual inspections are required to maintain status - Members described it as "a lot of work" but ultimately "doable" and "very worth it" for access to larger retail channels Members who pursued it without outsourced production found it a necessary headache to unlock major retailer relationships, particularly for RFP processes.
Which UK laboratories offer alcohol testing services and what do they cost?
Members rely on a small set of established labs for alcohol testing. **Campden BRI** is widely used by the community. **Brewlab** is recommended as a reasonable option with formal analysis services available through their website. **Tatlock and Thomson** is another option; members report paying around £200 per year for annual vodka testing through this provider. **i2fast** is also listed as a testing option. Members recommend checking each lab's specific analysis services and getting quotes based on your testing requirements (alcohol content, composition, etc.).
What are the EPR thresholds and exemptions for packaging in the UK?
The UK's Extended Producer Responsibility (EPR) scheme has a **dual threshold exemption**: you must be over **£1m in annual turnover AND produce over 25 tonnes of packaging waste** to be in scope. If you fall below either threshold, you're exempt. - **Threshold detail**: 25 tonnes of packaging waste equates to approximately 41,000 glass bottles at 600g each. This applies at the **manufacturer level**, not the distributor or wholesaler level—so many smaller brands remain exempt even if their products are distributed by larger wholesalers or traded distributors who themselves exceed the threshold. - **Implementation timeline**: A Designated Managing Organisation (DMO) is being appointed in April, with fees becoming volume-based and applying from **27 October** onwards. At that point, all producers, wholesalers, and other supply-chain participants above the exemption threshold must be registered. - **Official guidance**: The government's full guidance is available at gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do **Note**: The exemption structure means the threshold is clearer for manufacturers than for other actors in the supply chain (wholesalers, distributors), and members confirmed the manufacturer-level application of the thresholds.
What are the typical timelines and difficulty levels for achieving B Corp certification in the drinks industry?
B Corp certification is more straightforward than many expect, though timelines vary. **Timeline:** Members reported around 18 months for completion, though one member noted this was during a particularly long queue period at the time of their application. Expect some waiting time as part of the process. **Difficulty:** The process is not as painful as its reputation suggests. Members consistently noted that the **B Corp Assessment itself is a valuable business tool** — the real benefit lies in how it forces reflection and improvement across multiple aspects of operations. Several members reported finding the experience genuinely useful for analysing and improving their business rather than burdensome. **Getting started:** Members recommend reaching out to others who have completed it (several in the community are happy to discuss their experience directly). Multiple members noted they are willing to chat through the process one-on-one. **Note on requirements:** One member queried whether you must be listed to begin — this wasn't clarified in the discussion, so check directly with B Lab or consult with members who have gone through the process recently.
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.
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.
What is the B Corp certification process and timeline for drinks companies?
B Corp certification takes significant time to complete. The process typically takes **over a year**, with no way to speed it up despite B Corp working on shortening timelines and changing the whole process this year. Key requirements and tips from members: - **Written documentation** — have comprehensive written documents for everything, as this helps with validation during the accreditation process - **Score proximity matters** — if your current impact score is close to 80, certification may be challenging, as you'll likely lose a few points during the accrediting process and may fall short of the threshold - **No expedited contacts** — members confirmed there are no insider contacts or ways to speed things along Members recommend starting preparation early and being thorough with documentation, as the validation process is thorough and lengthy.
What are the regulatory and trademark rules around spirit drink classifications, and how do companies navigate category definitions?
Spirit drink classification sits in a murky space where trademark law and industry standards don't align well. Here's what members have encountered: **Regulatory enforcement:** Enforcement typically falls to local authorities and trading standards bodies, and may only trigger if complaints reach them or major retailers like Tesco demand correct labelling. This creates a compliance gap where non-compliant products can remain on shelves unless actively challenged. **Category definition vs trademark:** The trademark system operates independently of spirit drink industry definitions, so trademark holders rarely consider (or know) the technical category rules. This mismatch means products can be registered with names that wouldn't comply with spirit drink regulations—and changing this is difficult once locked in. **Portman Group guidance:** Members were advised by the Portman Group to avoid using numbers in spirit drink names, as the average category strength is still undefined. Using a number now could later tie you to rules that contradict it if category standards solidify. **Real-world examples of the grey area:** Products like flavoured vodkas with added citric acid, and bottles marketed as one spirit category but at ABV levels that technically belong to another, have remained on shelves. Some use this ambiguity as a selling point. Retailers and regulators appear to tolerate these products unless pressured or unless consumer complaints escalate. **Key caveat:** This is uncharted territory. The overlap between trademark registration, spirit drink regulations, and enforcement discretion creates uncertainty. Members noted this would benefit from formal Kindred discussion.
How does Small Brewers Relief work under the new Alcohol Duty system, and what will the effective rate be for qualifying producers?
Small Brewers Relief (SBR) continues under the new duty rates, but the relief mechanism has changed. Rather than a simple 50% reduction on the standard rate, there is now a graduated formula that applies differently depending on your production volume. **How to calculate your rate:** - The standard duty rate for beer 3.5–8.5% ABV is £21.01 per litre of alcohol - **Gov.uk calculator** — Use the official HM Revenue & Customs calculator at https://www.gov.uk/guidance/how-to-work-out-your-alcohol-duty-rates-if-youre-eligible-for-small-producer-relief, which inputs your product type and annual production volume to determine both the standard rate and your SBR rate - The guidance page includes worked examples showing how the relief is applied to different brewery sizes - Members confirmed that under the previous system, breweries producing under 5,000HL paid 50% of the standard rate, but the new system uses a formula-based approach (particularly for spirits, though the calculator handles beer separately) **What you should do:** - Rather than assuming the old 50% relief applies, input your own figures into the gov.uk calculator to see your actual rate - The calculator is the authoritative source for your specific circumstances
What are typical fees and minimum terms for obtaining Movement Guarantees through surety providers?
Movement Guarantee premiums typically start at a £1,000 minimum annual fee, regardless of the guarantee amount requested. Members report significant variation in pricing and terms depending on the underwriter. **Specific quotes members have received:** - **AON** (contact: james.ellison@aon.co.uk, underwritten by Aviva) — £1,000 minimum annual premium with £20k minimum surety requirement - **HCC through Nationwide Sureties** — quoted fees described as "way over" expectations, specific amount not disclosed - Anonymous provider — quoted £1,500 for a £2,750 guarantee over two years **Key observations:** - The £1,000 minimum fee applies even for smaller guarantee amounts (e.g., £20k) - Two-year terms appear available but pricing varies significantly - Members recommend shopping around, as quotes vary substantially between providers **Caveat:** The sample of quotes is small and anecdotal. Pricing likely depends on your business profile, guarantee amount required, and underwriter appetite. Getting multiple quotes from different brokers is essential.
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.
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.
What compliance and labelling specialists should we use for spirits, and what are the legal requirements for labels on drinks for private events?
For compliance and labelling expertise, members recommend consulting the **WSTA** (Wine & Spirit Trade Association) if you're a member, and the UK government's official guidance at gov.uk/guidance/labelling-spirit-drinks. For international market expansion, **Ashbury** specializes in compliance support across different markets, though members note they are expensive but deliver good service. For nutritional information on samples not for sale (e.g. private event giveaways), members report that labelling requirements may be less strict than for commercial products. One member's experience with a previous business showed that unlabelled product was acceptable for small-scale sampling as long as nutritional information and allergen details were made available to people at the point of sampling. However, members emphasize this was very small-scale experience and should not be taken as definitive legal advice—checking gov.uk guidance or consulting a specialist like Ashbury is recommended for certainty.
What flexibility exists for spirits bottle sizes in EU markets like France, Spain, and Italy—can craft brands use 750ml instead of the standard 700ml?
EU spirits regulations technically mandate 700ml as the standard size, but enforcement varies significantly by country and market position. **Smaller and niche craft brands often operate with 750ml bottles in practice**, particularly through distribution into Germany and other EU markets, as regulators tend to overlook non-major producers. However, this is informal tolerance rather than official flexibility—having to maintain two bottle sizes (700ml and 750ml) remains a significant operational burden for craft brands. Members noted this is an ongoing frustration for the sector, especially compared to recent US TTB flexibility on alternative spirits sizes. There is currently no formal EU or UK framework allowing size variation, though pressure for change is building within the craft spirits community.
What are the costs and procedures for exporting spirits from the UK to Monaco when only registered in the UK?
Exporting to Monaco from a UK-only registration is possible but expensive and complex. Members strongly recommend using a distributor or logistics consultant rather than attempting direct export. **Recommended contacts and options:** - **MPR** — can handle the export route from the UK and is noted as more cost-effective than alternatives - **La Rue** — recommended as a consulting option for Monaco export logistics - **Krupa consulting** — another consulting firm members suggested for this route **Cost expectations:** Monaco export logistics are significantly expensive. Members reported costs ranging from $5,000–$30,000 per month depending on the operation, with one member noting they had paid $10,000–$5,000 per month. Members warned "way too expensive" for direct handling and "do not recommend" attempting this without professional help. **Caveat:** The community consensus was strongly against attempting Monaco export without professional support, particularly for small shipments (e.g., 20 cases). Using a licensed distributor or consultant is the standard approach.
How do you claim back UK excise duty that has already been paid on stock that is subsequently exported?
Duty drawback on already-duty-paid stock is possible but requires strict compliance with HMRC procedures. Members recommend: - **Excise Notice 207** — the key document outlining the exact procedure, timescales, and evidence requirements. Follow it precisely or your claim will be rejected. - **Warehouse the stock for export** — you need to maintain detailed supporting documentation of the original duty payment and the export transaction. Gather a full dossier of evidence before submitting. - **Tax stamps** — confirm whether your UK stock carries tax stamps, as this affects the claim process. Caveats: HMRC's requirements are strict and the process can be bureaucratic ("get ready to share your inside leg measurements with HMRC"). An alternative some members suggested is to arrange future exports on an underbond basis (duty-unpaid) rather than claiming back on already-duty-paid stock, which avoids the drawback process entirely.
How long should physical product samples and batches be retained for quality and compliance purposes?
Members retain samples for varying periods depending on business needs and risk profile. - **7-year retention** — one member keeps all batch samples for this duration - **2-year retention** — another keeps samples for 2 years as standard for both customer and own-brand products, extending to longer periods for slow-moving lines where shelf-life or quality tracking is a concern - **Batch-by-batch archive** — one member retains every batch ever made, suggesting comprehensive record-keeping as an option for traceability and quality assurance No specific regulatory requirement was cited in the discussion. The variation suggests retention policy is driven by individual business risk tolerance, customer service needs, and slow-stock management rather than a fixed compliance baseline.
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 do I need to know about FDA facility registration when exporting spirits to the US, and should I register my own facility or use my co-packer's registration?
FDA registration is facility-based, not company-based. When exporting to the US, the registration is linked to the actual production site—so if you use a co-packer, their FDA facility registration is what matters. **Key points members shared:** - The FDA requires facility registration (not a separate exporter registration) - If you outsource production, you use your co-packer's FDA number - **Critical for customs:** Ensure the FDA facility registration number appears on all commercial invoices—customs brokers sometimes miss this, which can cause holds at port - Some members offer FDA filing services for their clients as part of their offering **Warning:** Double-check with your customs broker that the facility registration is included on export documentation; this appears to be a common point of failure that delays shipments at US ports.
What should I do if I've moved location and need to update my Alcoholic Products Producer Approval (APPA)?
When you relocate your drinks production business, you must proactively notify the relevant authorities of your new address—don't assume the novation of licenses covers this. **Key steps members have reported:** - Notify authorities of your location change before or immediately after moving; members found they should have advised them during the move process - Expect written confirmation by post; check you're receiving their mail (members noted that if post isn't arriving, the authority may have the wrong address on file) - Allow time for processing; members reported timelines of around 6 months from the location change, with written notification of the new APPA letter promised within specific windows (e.g. "by 25th Feb") - If you don't receive expected correspondence by the stated date, chase them proactively **Caveat:** The discussion contains limited detail on formal process steps. Members emphasise the importance of proactive communication with the authority to avoid the situation of discovering after the fact that you should have notified them.
Do founders need to disclose personal directors' loans when raising SEIS or EIS funding?
Yes, personal directors' loans must be disclosed when raising SEIS or EIS funding. This is both a legal and practical requirement. **How disclosure happens:** - **SeedLegals** — directors' loans and their conditions appear as part of the formal disclosures letter required during the fundraising process - **Balance sheet** — the loans are shown in your company's financial statements, which investors will review - **Seedrs** — when you drill into the detailed information on Seedrs (a common platform for these rounds), personal investment details are visible **Legal basis:** Directors have a fiducial duty to disclose any loans they have made to the company and the terms attached to them. This is a formal obligation, not optional. **Why this matters:** Members noted that disclosure can highlight disparities between founder skin-in-the-game and investor cash contributions, which investors will factor into their decision-making. One member reflected on the difficulty of equating years of unpaid work against cash investment, but the consensus was that transparency is required regardless.
What practical steps should UK spirits brands take with labelling and business registration when selling into EU markets after Brexit?
UK brands selling to the EU post-Brexit need to navigate labelling and business structure requirements carefully. Members' experience suggests the following approach works: - **EU warehouse registration** — Several members operate successfully via an EU-registered business entity (e.g. in the Netherlands), which significantly reduces rejection risk at borders. This appears to be the most reliable route. - **Label address switching** — Once you have an EU registered business, add that address to the back label rather than the UK business address. This simple change has prevented stock rejections for members who implemented it. - **Invoicing from EU entity** — Members report that simply adding the EU address to the label and continuing operations "as per" (without separate bank accounts or formal accounts) has worked; however, confirmation on whether formal invoicing from the EU company is legally required would be worth verifying with your accountant. - **Stock rejection risk** — At least one established brand (Chase) had stock turned away from Spain and Italy immediately post-Brexit, suggesting early implementation of the EU entity structure is advisable to avoid delays. **Caveat:** The discussion suggests practical workarounds rather than definitive legal guidance. Members recommend speaking to your accountant about formal invoicing and accounting requirements for an EU-registered entity, as the excerpts don't fully clarify those obligations.
Has anyone experienced R&D tax relief claims being retrospectively overturned or challenged by tax authorities after initial approval?
Yes, members have experienced R&D tax relief claims being retrospectively overturned. One member reported having a claim overturned for FY 2022 (with two successful claims in prior years), resulting in having to repay £17,000. Another member confirmed a similar experience. Members who faced overturned claims noted that challenging the decision appeared to involve significant administrative burden, with at least one deciding not to pursue an appeal due to the workload involved. Members experiencing this issue are available to discuss their experiences directly.
What security and insurance requirements are needed for a duty-suspended distillers licence?
Security requirements for a duty-suspended distillers licence depend on your case officer and bond level, but CCTV surveillance and other physical security measures are typically expected. The key is ensuring your insurance covers the operation. **Security approach:** - 24-hour CCTV surveillance is commonly required, though exact specifications may vary by case officer assessment - Physical security requirements should be confirmed with your case officer during the licensing process - **Insurance coverage is critical** — verify with your insurance broker that your policy covers duty-suspended stock and the security arrangements you're proposing. If you're properly insured, there's minimal financial risk to the authorities losing any bond - Some operators have found that being well-insured can reduce pressure on other security specifications, though this isn't guaranteed **Recommendation:** Contact your case officer early to clarify the specific security parameters they'll require, then work with your insurance broker to ensure your policy aligns with those requirements before submitting your application.
What are the options for incorporating HMRC duty stamps into back labels, and what are the timelines and process involved?
Members describe two main routes: incorporating duty stamps directly into printed labels (faster, cleaner), or applying physical stamps post-production. **Direct incorporation into labels:** - You must obtain a CD-ROM from the HMRC Duty Stamps office and send it to your label printer, who incorporate the stamp digitally into the design before printing - **Label Apeel** (contact James Label Apeel) has been specifically praised by members for making this process straightforward - **LabelTech** (based outside Dublin, Ireland) is recommended as an alternative for smaller label runs to avoid overstock; they handle the CD-ROM process - Timeline: Registration for your own UK duty stamp number takes approximately 2 weeks, plus another week for the stamps/CD-ROM to arrive (based on a French distillery's experience). Printed labels then arrive on normal lead times - Important caveat: obtaining a CD-ROM from HMRC reportedly prevents you from ordering labels without the stamp incorporated—you cannot get both options simultaneously - You need either your own UK duty stamp registration or access to your importer's duty stamp number; the registration process is not described as onerous - You will need a UK duty representative to take responsibility for the CD-ROM **Post-production application:** - **LCB** applies duty stamps for a fee post-production, but typically causes 1–2 week delays before product is available for sale **Important caveats:** - Duty stamps are scheduled to be phased out in 2025; consider the longevity of large label orders - The replacement process for post-2025 compliance is not yet clear, though there is mention of potential on-line engraving during production - If you use a non-UK printer (e.g., in Oaxaca or Mexico), incorporating duty stamps into labels becomes more complex; applying physical stamps locally may be easier than attempting label incorporation from abroad
What should be included in due diligence procedures and AWRS licensing interview preparation for contract brewers?
Members preparing for AWRS licensing interviews emphasise that due diligence goes beyond simply checking that your contract brewing partner has paid duty. Here's what the community recommends: **Getting interview-ready:** - **Have a written due diligence policy in place** — this is described as "the key thing" by members who've recently completed interviews. Several members note that retailers' policies follow a similar template; asking existing members to share theirs can help you develop one quickly. - **Connect with experienced practitioners beforehand** — members recommend speaking with people who've recently gone through the interview (such as those who've worked with the LBA, the Licensing Body for Alcohol) to understand what questions to expect and how to present your process. **Due diligence scope for contract brewers:** - Verification that your contract brewing partner has paid duty is a starting point, but members indicate "much more is needed" - Your policy should document the due diligence you've conducted on your contract partner(s) — their compliance track record, financial standing, and operational controls - Written procedures demonstrating how you'll monitor and verify ongoing compliance **Caveat:** One member explicitly notes "#notalaywer", so while this reflects community experience, professional advice from a licensing specialist is recommended for your specific circumstances.
What is the process for obtaining FDA registration for a manufacturing facility to export spirits to the United States?
FDA registration for a canning/manufacturing facility is achievable but administrative. Most members use a US agent to handle the application, though it can be done in-house. **Key approaches:** - **Liberty Management Group** — members have used them as a US agent to handle FDA registration applications and act as your agent for a fee - **Self-service route** — members report their ops team has completed the registration themselves; it's doable but time-consuming - **Local US contacts** — some members have engaged individuals in the US (e.g. Texas-based) to manage the application locally **Essential requirement:** Your canning/manufacturing company must be set up as an FDA food facility registered. You will need a US agent regardless of whether you handle paperwork yourself or outsource it entirely. **Next steps:** Contact members directly for introductions to their FDA contacts or service providers — several members offered direct introductions within the community.
What are the practical strategies and service providers for managing EPR (Extended Producer Responsibility) compliance and costs?
EPR compliance is creating significant cost pressures for drinks brands, with some facing six or seven-figure annual impacts depending on sector. Members are using several practical approaches: **Service Providers & Consultants** - **Ecosurery** (Bristol) — recommended by multiple members for managing EPR registration and compliance - **CLARITY** — a consultancy that has identified potential cost mitigation strategies and is helping brands develop collective responses **Cost Mitigation Tactics** - **On-Trade exemption letters** — Some consultancies have identified a potential route to reduce costs: obtaining written confirmation from end-on-trade customers (not wholesalers) stating that bottles cannot be removed from the premises where sold. Members report most customers are willing to sign these letters. - **Collective industry approach** — Several members are forming a united group with competitor brands to submit appeals to DEFRA, though this takes time. A large soft drinks brand has already faced investigation for attempting to exclude on-trade from waste returns to avoid the levy. **Key Caveats** - Retailers and wholesalers are responding inconsistently — some are collaborating with suppliers on costs, others are delaying decisions and leaving suppliers to fund the interim gap. - Amazon and other major online platforms have notified some sellers of EPR tax increases and requested price decreases; members report some suppliers are absorbing these rather than passing them on. - The on-trade letter strategy may face scrutiny (DEFRA has already investigated similar approaches by larger brands). - Joining a collective buying group or consultancy arrangement can help coordinate strategy but requires time investment. Members advise monitoring DEFRA's response to appeals and collective challenges.
How can we get Amazon's licensing approval using a warehouse premises licence?
Members confirm that using a warehouse premises licence is a viable route to satisfy Amazon's licensing requirements, though it requires persistence. The process typically involves multiple resubmissions before Amazon accepts the documentation. **Key steps members recommend:** - Upload the **warehouse premises licence** (e.g. from your storage partner) - Include your **personal licence** - Provide your **contract with the warehouse operator** (e.g. Law Distributions) - Submit your **most recent invoice** from the warehouse to prove you actually store stock there - **Keep referencing the earliest case reference number** in all communications to maintain continuity - **Escalate to their manager** and persistently state that all documentation is in place; members report Amazon will eventually give in **Caveats:** Expect this to take considerable time and patience. One member reported needing approximately 40 resubmissions before Law Distributions' premises licence was accepted. Don't give up after initial rejections; persistence and escalation are key.
Should we use an agent to handle SEIS/EIS applications or can we complete them ourselves?
Members strongly recommend using a specialist agent rather than attempting SEIS/EIS applications in-house. The consensus is that the process is complex enough that doing it wrong is a real risk. **Recommended approach:** - **Seed Legal** — mentioned as a trusted agent for SEIS/EIS applications **Key considerations:** - Multiple members advised "always use an agent — it's too easy to get wrong" - If you're claiming Capital Gains deferral relief (deferring gains from previous CGT-liable transactions into an EIS investment), this adds complexity and makes professional guidance even more important - Relief is claimed through the EIS3 certificate form via your tax return, similar to income tax relief claims - If you've already paid CGT on a gain before deploying it into EIS, your accountant will need to advise on the best reclaim route **Caveat:** While the forms themselves (EIS3 cert) are theoretically completable, the strategic planning around Capital Gains deferral and ensuring compliance makes agent involvement the safer choice.
How do I find distributors and importers to get my products into Mediterranean markets like Italy and Ibiza?
Getting stock into Mediterranean markets is genuinely difficult and requires significant time and regulatory work. **What members learned:** - **Italy**: Members have asked repeatedly but report there's no standout distributor option. One member was sponsoring an event in Milan and hoped to make connections in person, but the community couldn't provide specific recommendations. The usual advice is that success depends heavily on who handles your goods through the channel. - **Ibiza/Spanish islands**: One member took two years to crack this and reports it's "virtually impossible" without proper setup. The barriers are steep: - You need **both an importer and a distributor** signed up and committed - **Spanish-specific stickering and label compliance** is mandatory for customs clearance - Another member tried with "committed decent large customers" but couldn't find a quick fix despite significant time investment **Key warnings from experience:** - Don't expect rapid responses or clear guidance from potential partners in the region—one member reported responses that "were always a bit off direction" from their questions - Members with board-level regional contacts still couldn't identify reliable options - The regulatory and logistics complexity means this isn't a side project; it requires dedicated effort and proper compliance work upfront If you're serious about either market, the recommendation is to reach out to members who've completed the process (they've offered to share learnings privately), but budget significant time and be prepared for the possibility of no viable route.
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.
What are the key differences between UK and EU labelling regulations for alcohol products?
The UK and EU have broadly similar labelling rules for alcohol, but there are several important differences to be aware of: **Units and tax stamps:** - The EU does not require units to be displayed on labels, whereas the UK does - The UK requires a tax/duty stamp on labels; the EU generally does not (with exceptions including Italy) - If exporting from the UK to the EU with a UK label that includes a tax stamp, you must place a sticker over the duty stamp to comply - From 1 May onwards, there is no issue with obliterating the duty stamp when exporting from the UK **Practical approach:** Members recommend checking with your distributor or legal advisor about the specific requirements for your target EU markets, as rules can vary by country (e.g. Italy has its own tax stamp requirements). The similarity of most rules means a single label design can often work across both markets with minor modifications like the sticker solution for duty stamps.
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.
How should R&D tax credit claims be managed, and what specialists or accountants offer the best value?
Members report that R&D tax credit claims require significant internal work regardless of which specialist you use—don't expect a consultant to do all the legwork for you. Most members have found it pragmatic to route claims through their existing accountants for sign-off and final calculations rather than hiring dedicated R&D specialists, who often charge unpredictable rates and may push work back onto you anyway. **Typical approach:** Use your regular accountant to handle the claim preparation, paperwork, and enquiry insurance. Members report paying around **15% of the claim proceeds annually** for this service, which feels reasonable given the current variability in specialist pricing across the market. **Note on pricing:** The R&D tax credit market remains quite volatile in terms of what different firms charge—there's no clear standard rate. Some members are keeping an eye on potential shifts as the R&D claim structure itself may change, which could eventually rationalise pricing. If you want a personal recommendation for a specialist, ask in the group for a DM introduction, but go in with realistic expectations: you'll still need to document your R&D activities and rationale internally; the adviser will help structure and sign off, not do the archaeology for you.