Where Now for WOWGR?

What is WOWGR?

Interested in storing duty-suspended alcohol in the UK? You’ll likely need WOWGR approval.

The Warehousekeepers and Owners of Warehoused Goods Regulations (WOWGR) establish the legal framework for the storage of alcoholic products under a “duty suspension” regime within approved excise warehouses in the UK.

The concept of duty suspension refers to the authorised storage, holding, or movement of goods liable to excise duty without the immediate payment of that duty to HM Revenue & Customs (HMRC).

This system offers significant operational and cash-flow advantages to businesses by deferring the payment of excise duty until the alcoholic goods are released for consumption or exit the excise warehouse for their final destination, typically for bottling or sale.

Reforms to WOWGR in 2025

Lets break down the 2025 legal changes:

With the commencement of the Excise Duties (Miscellaneous Amendments and Revocations) Regulations 2024, effective from 3 March 2025, the operational dynamics for businesses involved in the alcohol supply chain changed:

• Prior to 3 March 2025: WOWGR stipulated registration requirements for three distinct categories of entities: warehousekeepers, who operate excise warehouses; registered third-party owners of excise goods in those warehouses; and duty representatives, who acted as agents for overseas owners.
• From 3 March 2025: only warehousekeepers who operate excise warehouses are legally mandated to obtain and maintain WOWGR approval from HMRC. Note that the warehouse in question must also be approved by HMRC.
• From 1 February 2025: If you are producing alcohol (such as distilling spirits), and hold duty-suspended alcohol at your production premises as part of the production process, you do not need separate WOWGR approval. The Alcoholic Products Producer Approval (APPA) from HMRC is sufficient for both production and storage under duty-suspension.
• If you are approved under APPA, you may also still seek parallel WOWGR approval for a trade facility warehouse if it makes sense for your business. For example, if you store alcohol at a different premises to the production premises.

Unintended Consequences

What do the WOWGR changes mean for the industry?

Historically, the registration of owners and duty representatives by HMRC provided an indirect form of vetting, offering a degree of comfort to warehousekeepers regarding the legitimacy of the goods and their owners

Following the reforms, the responsibility for ensuring the integrity of the supply chain now rests more heavily on the warehousekeeper.

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 WOWGR 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

• You will require WOWGR approval if you intend to manage a UK excise warehouse storing duty-suspended alcohol in a UK warehouse.
• You no longer need approval as a third-party owner to store duty-suspended alcohol in someone else's warehouse.
• Non-UK established businesses do not need to appoint a duty representative to store alcohol in a third-party UK excise warehouse.
• If you only hold duty-suspended alcohol as part of the production process, on your production premises, you likely only need APPA approval rather than WOWGR.
• A business planning to move alcohol under duty suspension requires separate approval as a registered consignor .

Need WOWGR approval?

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