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.
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.
What are the legal and regulatory requirements for compounding or rectifying spirits at home with duty-paid alcohol?
The HMRC rectifier licence requirement has been removed, meaning you can legally compound or rectify duty-paid spirits without a licence. However, there are several other legal and operational considerations to be aware of: **Regulatory and compliance requirements:** - You still need **AWRS registration** (Alcohol Wholesaler Registration Scheme) if you're operating as a business - **Health and safety regulations** apply, including ATEX (equipment in explosive atmospheres) and DSEAR (dangerous substances and explosive atmospheres regulations) if working with alcohol vapours - **Record-keeping, batch control, and quality control systems** are essential and will be expected by regulators **Financial and duty considerations:** - There is **waste from duty-paid alcohol** that you may be able to recover duty on — clarify this with HMRC as it could affect costs - **Bonded warehouse facilities** (to operate on a duty-suspended basis) remain much more difficult to obtain than the old rectifier licence was, so duty-paid compounding is the more practical route **Strategic considerations:** - **Contract distilling is often significantly cheaper** than in-house production (members report paying around £5 per bottle for contract work), so the decision to make in-house should be driven by story, origin, or product testing rather than cost - In-house compounding can work well for **testing new products or building local origin stories** before committing to larger-scale production **Member caveats:** While the licence removal is a legal change, it was not considered a major game-changer by members, as the rectifier licence was already relatively easy to obtain. The real barriers (bonded operations, H&S compliance, systems) remain unchanged. Members recommend speaking to a specialist about the detailed operational implications before starting.
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.
How strict is HMRC enforcement on the three-year trading window requirement for SEIS tax relief eligibility?
HMRC has tightened its approach to SEIS and EIS compliance significantly over the past 18 months. Members report that HMRC is now "pretty strict" on the three-year trading window requirement. **Key points:** - **EIS3 certificate applications** without recent advanced assurance are increasingly being questioned by HMRC, suggesting closer scrutiny of the trading history and timeline documentation. - For specialist or contentious cases, members recommend consulting **Philip Hare**, described as expensive but highly effective at arguing technical SEIS/EIS points with the tax authority. - The general consensus is that you should assume HMRC will enforce the requirement rigorously rather than take a lenient interpretation. **Caveat:** This is based on members' recent experience rather than published HMRC guidance changes. If you're close to or crossing the three-year threshold, specialist advice is worth the investment.