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 licensing do I need to sell alcohol direct-to-consumer through third-party platforms like Amazon?
The licensing requirement depends on where your fulfilment happens. If you're selling D2C through third-party platforms like **Amazon**, you typically need a premises licence because the platform treats it as selling directly to the public. However, members have found workarounds: - **Using a bonded warehouse's premises licence** — Several members use a third-party bonded warehouse for fulfilment and leverage their existing premises licence rather than obtaining their own. This is the most common approach. - **Operating from your own licensed premises** — Some members set up D2C fulfilment from a licensed premise they own (which can have a different trading name from your brand). - **Selling from your own website** — Members report that D2C sales via your own website do not require a premise licence, only third-party platform sales. **Important caveat**: Amazon in particular has been strict about this requirement. Members who initially faced rejection were told to persist with appeals, providing all correct information and requesting escalation to a supervisor—it reportedly took 9–10 messages for some to get approval. Keep emphasising that fulfilment is from a licensed premises (either your own or a bonded warehouse's), and you should eventually get through.
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 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 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 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 a premises license to rectify or compound duty-paid spirits in a hired facility for one-off production runs?
No premises licence is required for rectifying or compounding duty-paid spirits, even if you hire a facility for short-term production runs. A premises licence enables you to *sell to the public* but has no bearing on your production activities themselves. Members confirmed this is correct, and noted that you can hire a facility without a premises licence for a month to produce and bottle your duty-paid spirits without issue. For specific guidance, contact your local licensing body (e.g. LCB Sawston if in that region).
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.
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.
What should I do if Amazon classifies my non-alcoholic drink product in an alcohol category, requiring an alcohol licence to sell?
Amazon's category system can incorrectly classify non-alcoholic drinks as alcoholic products, which then triggers licensing requirements you may not actually need. Rather than pursuing a full alcohol licence (which HMRC typically won't issue for non-alcoholic products), the recommended approach is to reclassify your product. **Key actions:** - **Reclassify with Amazon** — Push to move your product out of the alcohol category into 'non-alcoholic gifts' or another appropriate category. Members note that Amazon doesn't have a straightforward category for non-alcoholic drinks, but reclassification is simpler than obtaining an alcohol licence. - **Contact Amazon Seller Support** — Be prepared for a slow process; members report Amazon can be difficult to work with on category disputes and it may take months of back-and-forth. **Caveat:** HMRC will not issue an alcohol licence for a non-alcoholic product, so pursuing that route is a dead end. The frustration here is Amazon's category taxonomy, not regulatory requirement.
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.
What are the regulatory and practical requirements for operating self-service or automated alcoholic beverage dispensing systems in the UK?
Self-service alcohol dispensing is heavily constrained by UK regulations. **Weights & Measures Act** requires all beers, wines and spirits to be sold in pre-defined measures only—gin must be 25ml or 50ml, wine 125ml/175ml/250ml, etc. This means self-service systems must be pre-loaded or calibrated to dispense only these fixed amounts (similar to a coffee machine), rather than allowing free-pouring. Beyond measurement, there are two critical licensing compliance issues: - **Age verification**: Challenge 25 can be managed by making events over-18s only, removing the ID check requirement at point of service. - **Intoxication assessment**: This is the unresolved problem. Licensing law requires the server to assess whether a customer is already too drunk before serving. With no staff present, there is no mechanism to perform this check. Members noted this as the fundamental blocker—automatic breath tests or coordination tests remain theoretical and impractical. **Practical observation**: A member who used a self-service station at Twickenham noted additional user-experience issues: consumers unfamiliar with pouring often create excessive head, spill beer, or under-pour, resulting in poor satisfaction. **Wider context**: Trading Standards research (2024) found over two-thirds of UK beer and wine is short-measured even in supervised bars, suggesting accuracy in automated systems may be difficult to guarantee and audit. Members suggest consulting **AWRS** and **WOWGR** frameworks, though consensus was unclear on whether existing licensing covers this scenario. Contrast: Italy operates unsupervised beer vending machines, but UK law does not permit equivalent models.
What licensing and compliance requirements apply to selling alcohol on Amazon via 3PL fulfillment, and are there workarounds?
You cannot avoid the premises license requirement for Amazon alcohol sales—it applies whether you sell via 3PL or direct-to-consumer on your own website. However, the standard approach is to use a 3PL partner who already holds a premises license themselves, so the inventory sits under their licensed facility. **Key findings from the community:** - **Premises license is non-negotiable** — there is no workaround; Amazon requires it regardless of your fulfillment model. - **3PL route**: Use a 3PL that specializes in alcohol and already holds a premises license. Their license covers the stock held at their warehouse. - **Fodabox** — confirmed working solution; they handle many alcohol brands for Amazon and have software that integrates so orders flow directly into their warehouse system with no manual intervention. - **Bemakers** — one member is currently onboarding and sent their first shipment, though they note being "guinea pigs" on this (watch for updates). - **Caution**: Not all 3PLs will accept alcohol inventory, even if they hold a license. Several members reported being refused by 3PLs they approached. It's worth contacting multiple specialized operators. **Next step**: Identify 3PLs with existing alcohol brand experience and integrated Amazon connectivity rather than trying to negotiate with generalist fulfillment providers.
What are the regulatory requirements for sampling alcoholic beverages in public spaces in the UK?
Sampling alcohol in public spaces is technically regulated, but enforcement varies. Members note a pragmatic approach is common in the UK. **Regulatory framework:** - You technically need a **council license** to hand out samples in public spaces - If you have **music** playing while sampling, you'll also need **PRS/PPL music licenses** **Practical approach members use:** - Several members note the informal British approach: "Ask for forgiveness, not permission" — implying sampling often happens without prior formal permission - Enforcement appears inconsistent; members asking whether they "get fines or just asked to move on" suggests outcomes range from being told to relocate to no intervention - One member recommended: "I'd just do it, and apologise later" **Caveats:** - The discussion did not turn up a specific public resource listing legal sampling locations in London. Members asking for this resource suggests it may not exist or isn't widely known. Compliance risk depends on local council enforcement, which varies by borough.
Can we distribute vouchers offering free alcoholic drinks at our licensed venue?
The answer depends on your specific license conditions. **Several members reported that their venue licenses explicitly prohibit handing out vouchers for free alcoholic drinks.** You must check your own license conditions carefully, as the restrictions vary by individual license. One member confirmed "Ours specifically prohibits that," indicating this is a common clause. Before running any promotion involving free or discounted alcoholic drinks, review your premises license conditions or contact your local licensing authority to confirm what's permitted under your specific agreement.
Do all storage and warehouse locations need a premises licence, or only those used for retail sales?
Storage units used purely for trade sales (business-to-business distribution) do not require a premises licence. A premises licence is only required if you are fulfilling retail sales from that location. Members suggest checking with your local licensing authority to confirm the intended use of any new storage facility, as the distinction between trade-only and retail-facing operations determines the licensing requirement.
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.
Where should we publish our premises licence application notice and what is the process?
You are required to publish your premises licence application notice in a local newspaper serving your area. Members report that this is a mandatory but frustrating step in the licensing process. **Local newspaper publication:** - **Lewisham Gazette** — used by at least one member in South London; noted as expensive and operating with archaic processes, but necessary for compliance in that area. Members recommend identifying the equivalent local paper for your region (typically the main newspaper circulating in your local authority area) and contacting them directly about their licensing notice fees and timelines. **Caveats:** Members emphasised that the premises licensing system overall is outdated and frustrating. Budget for publication costs, which appear to be substantial. The process is a legal requirement so cannot be skipped.
What are the regulations and legal considerations for distributing alcohol samples in public spaces in the UK?
Members discussed sampling alcohol in public spaces like parks and transport hubs, with the consensus that closed miniatures are generally not prohibited by law in these settings. However, the community's practical approach reflects a permissive rather than strictly regulatory stance. **Key points from the community:** - Closed spirit miniatures in public spaces (parks, near tube stations) are not explicitly prohibited by law, according to member discussion - A formal **Guidance-Note-Product-Sampling.pdf** document exists and was shared in the group—this is the primary reference material members consulted - Members emphasized the importance of **not distributing samples to minors** under any circumstances - The community's de facto strategy is low-friction: hand out samples, and if challenged by authorities, apologize and relocate - Formal venue-based sampling (e.g., **The Whisky Exchange** on Great Portland Street) operates within clear commercial licensing frameworks and is unambiguous **Caveats:** The group's casual "forgiveness, not permission" approach suggests sampling in public spaces operates in a gray area. Members did not discuss local council bylaws, which may vary by borough or specific location. For any planned sampling campaign, consulting the formal guidance document (which members referenced) and checking local authority rules for the specific location is strongly advised.
What are the import license requirements and courier options for shipping alcohol samples to international destinations?
Shipping alcohol samples internationally requires navigating import licensing requirements in the destination country. FedEx will reject shipments without proper documentation, so alternative couriers and customs representation are essential. **Courier options:** - **DHL** — members report success shipping overseas samples with this carrier - **FedEx** — will reject alcohol shipments without import licenses in place **Required documentation and process:** - **EORI number** — you'll need this from UK Customs - **Customs representation** — you must arrange either direct or indirect representation (see UK guidance on customs debt liability: https://www.gov.uk/guidance/customs-debt-liability#types-of-representation) - **EFS Global** — a customs agent that can handle import/export documentation; they offer a "pay as you go" import service at https://efs.global/import-payg/ and their main site is https://efs.global/ **Alternative route:** - **Gerry's in Soho** — one member previously used this London-based supplier for sample shipping (though current details unclear) **Caveats:** Members noted that costs for proper customs clearance are "ridiculous," and the process is "a nightmare" to navigate. Non-alcoholic samples may have different requirements. Samples cannot simply "go under the radar" — proper licensing is mandatory for alcohol shipments.
What regulations apply to giving away free alcoholic beverages as promotional giveaways?
Free alcoholic giveaways are subject to licensing restrictions. Members discussing promotional sampling noted that **a Temporary Event Notice (TEN)** is required to legally distribute free alcoholic drinks at promotional events. One member referenced needing a TEN when planning a giveaway campaign that resulted in people openly carrying cans in public spaces (Waterloo area), suggesting this is the standard regulatory route for on-the-ground sampling.
What licensing requirements apply when selling alcoholic beverages on Amazon without a physical premises?
You cannot sell alcohol on Amazon as a direct registered seller without holding both a personal licence and a premises licence. Since most members do not operate from a licensed premises, the standard route is to sell through an existing licensed retailer who acts as the intermediary seller. **Third-party seller approach (most common):** - **Specialty Drinks** — established third-party seller that members use to list their products on Amazon - **Whisky Exchange** — handles Amazon listings and sales for member brands - **Master of Malt** — another established licensed retailer selling member products on Amazon - **31 Dover** — licensed retailer offering Amazon fulfilment - **Spirit Cartel** — operates a dedicated shop on Amazon for member brands **Alternative:** - **Amazon direct purchasing** — Amazon itself may buy stock and sell it directly through their own account (e.g. for Prime eligibility), which removes the licensing burden from you as the brand owner **Key caveat:** Members asked about fulfilment partners with bonded storage for e-commerce, but no specific recommendations emerged in the discussion. This may require separate inquiry with the third-party retailers above about their bonded warehouse capabilities.
What do I need to do with my WOWGR licence when relocating my drinks business to a different location?
You must update your WOWGR (Wholesale of Alcohol and Online Sales) registration **before** you move premises. This is a critical step that cannot be done after relocation — plan the WOWGR amendment as part of your relocation timeline to avoid any compliance gaps or suspension of your ability to operate.
Do I need an export licence to ship alcoholic beverages to EU countries?
No formal export licence is required for most alcoholic beverages (such as gin) shipped to EU countries, though you will need an **EORI number** (Economic Operator Registration and Identification) registered with HMRC. Members' practical experience: - **EORI number** — Required; register with HMRC before shipping - **FedEx** — Recommended by members for EU shipments; described as "very reliable" - Sample shipments are generally straightforward to arrange Note: Individual EU member states may have different regulatory requirements, so confirm with your specific destination country (e.g. Portugal) before shipping. The EORI number is the key administrative requirement on the UK side.