Despite our best efforts with Google search parameters, The Licensing Guys ™ receive about ten enquiries per week from the public asking us to challenge their Driving Ban, replace their Lost Driving Licence and occasionally sort out their TV Licence. However we sometimes DO receive enquiries about types of Alcohol Licences that we do not handle. These in the most come from Alcohol Producers, Importers, Shippers and Fulfilment Houses.
So: The time has come to discuss what the types of Licences that The Licensing Guys ™ do NOT do 😊!
OVERVIEW: Anyone who produces alcohol, moves alcohol under duty suspension, or stores alcohol under Duty suspension will likely need some of the items below, if not all, depending on the operation.
Since the introduction of the Alcoholic Products Producer Approval (APPA – part of the 2023 Alcohol Duty reforms), the UK licensing landscape has been streamlined. Instead of separate licenses for beer, wine, and spirits, producers now use a UNIFIED system.
For your fullest information, here is a little bit more depth into why these licences are required…
To produce and sell your own alcoholic products (beer, cider, wine, spirits, etc.), you generally need four distinct approvals/licences.
• Alcoholic Products Producer Approval (APPA): This is the single most important licence. It replaced the old separate registrations (e.g. Distiller’s Licence, Brewer’s Registration, Cider Maker’s Registration).
o What it does: Authorizes you to produce any category of alcohol and carry out activities that change ABV or product classification.
o Duty Suspension: The APPA allows you to hold the alcohol you produce in duty suspension at your approved production premises.
• Alcohol Wholesaler Registration Scheme (AWRS): If you sell your alcohol to other businesses (B2B), such as pubs, shops, or other wholesalers, you must be registered with HMRC under AWRS.
Note: You generally do not need this if you only sell to the public (B2C) or if wholesale is an incidental part of your production business (though most producers still register to be safe). Therefore we ALWAYS recommend that you obtain AWRS registration as the exemptions are extremely complicated and it is always best to be 100% covered for any eventuality.
The rules for storage depend on whether the “Duty Point” has been triggered (i.e. if tax has been paid).
Storing Your Own Product (Duty Suspended)
• Included in APPA: Your APPA approval automatically includes the right to store the products you produce in duty suspension at your approved production premises. You do not need a separate Warehousekeeper licence for your own site.
Using a Third-Party Warehouse (Duty Suspended)
If you want to store your duty-suspended products at a third-party facility (a “General Storage and Distribution Warehouse”), the following are required:
• Authorised Warehousekeeper: The third party must be approved by HMRC as an Authorised Warehousekeeper.
• Excise Warehouse Approval: The specific site must be an HMRC-approved Excise Warehouse.
• WOWGR (Warehousekeepers and Owners of Warehoused Goods Regulations): If you are the owner of the goods stored in a third-party warehouse, you must be registered as an “Owner of Warehoused Goods” under WOWGR.
o This allows you to keep your goods in duty suspension at someone else’s facility.
Moving Goods in Duty Suspension
• EMCS (Excise Movement and Control System): To move products between your approved premises and a third-party warehouse without paying duty, you must use the EMCS. This tracks the movement and ensures the duty is “suspended” during transit.
Where Next?
If you ever thought the Licensing Act 2003 was a bit involved, by now you must have concluded that the other Licences can be a maze of regulation too – and you’d be right.
Here at The Licensing Guys, we refer any such enquiries to our trusted partner – Matt SERVINI at the Craft Distilling Business. Do not be confused by the name of the business, as they handle much, much more than Craft Distilling. They help clients obtain the above listed licences, including developing diligence policies and other licensing requirements. They also ‘coach’ clients (ethically) on how to answer questions during HMRC interviews.
For small companies, they charge around £1,200 to obtain all of the above licences simultaneously. However, larger organisations with more complex supply chains will need an even more bespoke service.
You can contact Matt and his team directly using the below link:
If you need anything to do with Alcohol Licensing, why not be like our other satisfied customers and drop us an email or give us a call on 01432 700 024?
Click here to arrange your FREE consultation at a time that suits you!
Pst – if you like this, why not check out The Licensing Guys extensive knowledge base which is full to the brim with useful, practical or educational information on all things Alcohol Licensing.
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