All About APPA

What is APPA?

Interested in producing alcohol in the UK? You’ll likely need APPA approval.

APPA (Alcoholic Products Producer Approval) is the single UK approval that producers must hold to make alcoholic products (beer, cider, wine, spirits and other fermented products) in the UK.

Introduced as part of the 2024–25 alcohol duty reforms, APPA centralises and replaces the previous patchwork of product specific registrations and licences so that a single approval covers the business, activities and premises where alcohol is produced and (where authorised) held in duty suspension.

Under the new regulatory framework, APPA covers:

• The categories of alcoholic product you may produce (beer, wine, spirits, cider, other fermented products).
• The specific production related activities you may carry out (for example making from raw ingredients, changing ABV, changing product classification).
• The premises where you may carry out those activities, including any authorised areas for holding duty suspended stock.
  Note: Duty suspension refers to the authorised storage, holding, or movement of goods liable to excise duty without the immediate payment of that duty to HMRC.

Reforms to APPA in 2025

Lets break down the 2025 legal changes:

Before APPA, the approvals landscape was split by product and activity. Different registrations or licences existed for beer, cider, wine, spirits, and for activities such as rectifying/compounding or running an excise warehouse. APPA replaces those separate production registrations and licences with a single approval for producers.

Importantly, businesses that already held an approval or licence before 1 February 2025 were migrated into the APPA system — they did not need to submit a fresh application to keep producing. New producers from that date must apply for APPA before starting production.

Key changes in 2025:

• One approval, multiple products: APPA covers all categories and activities for which the producer is approved, removing the need for separate product specific registrations.
• Centralised risk checks: HMRC runs consolidated background checks (Companies House, credit checks, criminal record checks, trading history) as part of the APPA assessment.
• Duty suspension explicitly covered: APPA can include authorisation to hold duty suspended stock on the approved premises (so many producers will not need a separate excise warehouse approval to hold duty in suspension on their own approved premises).
• New digital services: HMRC announced an online route for applying and, separately, a new ‘Manage your Alcohol Duty’ digital service for returning and paying alcohol duty.

Who needs APPA — and who doesn’t?

You need APPA if you intend to produce alcoholic products

Production is broadly defined and includes activities that:

• Start from raw ingredients.
• Change the alcohol by volume (ABV) of a product (for example dilution or fortification).
• Change product classification.
• Produce an alternative product (for example by compounding or rectifying in duty suspension).

You do not need to apply for APPA if:

• You were approved to make alcoholic goods prior to February 2025. Your approval should have been automatically grandfathered into APPA. Contact HMRC if you are unsure.
• You only rectify or compound duty-paid alcohol. For example, you re-distil duty-paid, neutral grain alcohol with botanicals to make “London Gin”. Rectifying or compounding duty-suspended alcohol requires APPA. Contact HMRC if you are unsure.
• You only bottle or package alcoholic goods.
• You only hold alcoholic goods (even if prolonged holding gradually changes their strength) either duty-paid or in duty-suspension.
  Note: if you do not hold APPA and you wish to act as the warehousekeeper and hold duty-suspended alcohol on your premises, you must obtain WOWGR approval.
• You only import alcoholic goods.
• You only make alcoholic products of less than 1.2% ABV (these are not liable for alcohol duty).
• You only make beer, cider, wine or other fermented products for your own use. This exemption does not apply to spirits.
• You only make alcoholic products for research and development purposes. You must destroy the products after research and keep records for 6 years.

APPA vs excise warehouse approvals (the ‘WOWGR’ context):

A frequent point of confusion is the relationship between APPA and excise warehouse approvals (previously often discussed in the context of WOWGR).

• If you are a producer authorised under APPA, HMRC can (and commonly does) authorise you to hold duty suspended alcohol on your approved premises. In other words, APPA can cover the warehousekeeper activities carried out on those premises.
• If you do not have APPA but want to act as a warehousekeeper and hold duty suspended stock on your own premises, you will need the appropriate excise warehousekeeper approval from HMRC. Recent regulatory reforms to the rules for owners and warehousekeepers mean the historic ‘WOWGR’ terminology is now part of a revised framework.
• If you have APPA, but wish to store alcohol at a warehouse separately from your production site, you will also need the appropriate will need the appropriate excise warehousekeeper approval from HMRC.

There are significant business risks associated with non-compliance:

• Failure to conduct adequate due diligence or maintain proper records can result in the seizure of stock, leading to significant financial losses and operational disruption.
• HMRC can levy wrongdoing penalties for unpaid Excise Duty or VAT sums, which can be substantial. In instances of deliberate non-compliance, these penalties can be extended to directors or partners personally, leading to individual financial liability.
• The most damaging consequence of non compliance is the revocation of APPA approval. Such a revocation can have a cascading negative impact on a business's ability to operate, affecting other critical licenses and approvals, such as Movement Guarantees and approval under the Alcohol Wholesaler Registration Scheme (AWRS)

Final Recommendation

If you produce alcoholic products (or plan to start), treat APPA as a critical compliance threshold.

Start the process early - at least 45 working days before starting production - and make sure your business plan, due diligence policy and premises plan are complete and realistic.

If you only hold or bottle finished goods without altering them, confirm your exemption is valid for your activity; if you plan to act as a warehousekeeper without APPA, arrange the correct excise warehouse approval.

Need APPA approval?

Apply Now