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 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 are the impacts of Diageo's new wholesale policy requiring 30 designated wholesalers and £2m purchase thresholds for direct supply?
Diageo has implemented restrictive new wholesale rules that significantly reshape how independent retailers and smaller operators can access their products. The policy cuts direct supply access to only 30 approved wholesalers and requires cash-and-carry (C&C) customers to reach £2m in annual purchases (invoice value excluding VAT) to qualify for direct supply. **Key impacts:** - **Around 40 retailers lose direct access** — approximately 40 smaller wholesalers previously supplied directly by Diageo now must purchase Diageo products indirectly, often from their competitors, creating a significant market disruption and widespread upset in the trade. - **High purchase threshold barriers** — The £2m purchase requirement effectively excludes smaller independent retailers and venues from direct supply, forcing them into indirect channels. - **Concentration of power** — The policy limits distribution to only 30 designated wholesalers, reducing competition and potentially increasing margins across the supply chain. **Market observations:** Members noted this creates "a lot of upset in the trade" and flagged potential consequences: some traders are positioning themselves to exploit the disruption, and there's speculation that UK stock availability changes could create arbitrage opportunities at international borders. However, members also recognised potential opportunities emerging from the wholesale space upheaval for new entrants and alternative routes to market. **Note:** The community discussion did not provide a detailed list of the 40 affected wholesalers or the 30 approved ones.
What are the Post Office's restrictions on shipping alcoholic beverages domestically?
The Post Office allows domestic shipping of alcoholic beverages with two key limits: - Maximum **1 litre** per shipment - Maximum **70% ABV** — spirits and high-proof drinks above this threshold cannot be posted These are firm caps; anything exceeding either limit will be refused.
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.
What should you call a cocktail with sparkling elements (soda/bubbles) but no sparkling wine component?
The traditional naming convention distinguishes drinks by their sparkling element. Members recommend: - **Fizz** — the correct traditional term for a cocktail with soda bubbles but no wine component. This is the historically accurate nomenclature. - **Highball** — an alternative format for drinks served long with soda, also acceptable and commonly used. - **Spritz** — technically requires sparkling wine (Prosecco, Aperol, etc.) to be called a true Spritz. However, members noted that brands (including major retailers) are increasingly ignoring this rule and labelling soda-based drinks as "Spritz" anyway, particularly in non-alcoholic variants. Members observed that while the traditional rules dictate Fizz for soda-based cocktails, the market is shifting and some producers are using "Spritz" liberally regardless of whether wine is actually present. One member renamed their cocktail to "Fizz" to follow proper convention, though acknowledged the naming rules are increasingly not being followed in practice, particularly by larger brands.
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.
What is the correct process for declaring and exporting sample bottles internationally?
When exporting sample bottles internationally, use a commercial invoice that clearly declares the contents as samples rather than goods for resale, but assign a nominal value (e.g. €4.50 per bottle) rather than marking them as €0. This helps avoid customs complications. **Key practices:** - Mark packages clearly with 'Samples not for resale' or similar language - Use a priority shipping service for faster transit - Include a commercial invoice with sample status and nominal per-unit pricing stated **Sampling support:** Members have used **Hels Angels** (wearehels.com) to source people to help execute sampling campaigns if you need boots-on-the-ground support in target markets.
What are the key regulatory and market-entry differences when exporting spirits to Canada, and which provinces are easiest to enter?
Canada's liquor market is complex and highly fragmented by province, with significant differences in regulatory requirements and ease of market entry. **Regulatory and labelling requirements:** - Label content must meet Canadian standards; members recommend using an **additional acetate label** to cover off specific Canadian content requirements without reprinting. **Provincial market-entry difficulty:** - **Alberta, Saskatchewan, and Nova Scotia** are the easiest provinces to enter and require the shortest timelines. - **Ontario (LCBO)** is the largest volume opportunity but is the most difficult and typically takes 1–2 years to secure a listing. - Other provinces fall in between and are significantly harder to access than the easiest three. **Importer and distribution considerations:** - You must work with a local importer who understands Canadian pricing, margins (noted as "somewhat low"), and provincial government listing requirements. - In some provinces (e.g., Alberta), product is stored and distributed by the provincial government after import, which affects logistics and control. - Finding the right importer is critical—they must understand both private-import routes and how to navigate government distribution channels. **Overall positioning:** Members note Canada is "quite complicated" and "very similar to Nordics" in terms of regulatory complexity. The market is viable but requires patience and the right local partner, particularly if targeting the larger provincial markets.
What are the US beverage container deposit compliance requirements for UK-produced cans, and can the marking be printed on labels instead of etched?
For US exports, beverage container deposit compliance markings can be printed on the can label rather than requiring etching on the aluminium. This requirement became enforceable at state level from May 2024, with distributors able to refuse product or issue fines for non-compliance. Key points members shared: - **Label printing is acceptable** — the deposit compliance wording does not need to be etched into the can itself; printing on the label meets the requirement. - **State-specific deposit amounts** — Connecticut (CT) raised its deposit to 10 cents as of January, so labels must reflect the correct deposit value for each state where product is sold. Outdated labelling showing older deposit amounts creates immediate non-compliance issues. - **PFAS compliance is equally critical** — members emphasised that checking PFAS (per- and polyfluoroalkyl substances) compliance for US distribution is just as important as deposit marking. European suppliers only achieved PFAS-compliant availability at the end of 2023, so verify your canner's compliance status before exporting. Cautions: US bottle bill requirements are state-specific and subject to change (as the CT example shows). Ensure labels are updated whenever deposit amounts change in your target states, and confirm your UK canner understands and supports these compliance requirements.
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.