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 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.
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 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 is the typical HMRC approval timeline for transitioning from duty-paid to duty-suspended alcohol production?
Members report the process typically takes around **3 months from start to finish**. **Key points on current regulations:** - New WOWGR (Warehousing of Wine and other Goods Regulations) applications are currently not being processed by HMRC, though existing applications continue to be handled. - WOWGR is only required if using third-party contractors for production and storage; you do not need it to produce duty-suspended goods in your own warehouse. - You still require **Excise Warehouse Approval** even with the WOWGR abolition and transition to the new APPA (Alcohol Packaging and Production Approval). - For specific guidance on registrations and approvals, contact **nruwhseapprovals@hmrc.gov.uk**. **Useful contact:** The British Distillers Alliance (Alan Powell) has been coordinating this transition; members have access to their communications on the regulatory changes. **Caveats:** The regulatory landscape is actively evolving (WOWGR abolition, APPA introduction), and HMRC's processing of new applications was paused recently. Confirm current status directly with HMRC before submission.