If you sell alcohol to another business you may need to apply for approval for the Alcohol Wholesaler Registration Scheme (AWRS). HM Revenue and Customs (HMRC) introduced the scheme to tackle alcohol fraud.
You’ll face penalties if you trade without approval.
From 1 April 2017 if you buy alcohol to sell from a UK wholesaler, you’ll need to check that the wholesaler has been approved by HMRC and has an AWRS Unique Reference Number (URN).
From 1 April HMRC will provide an online look up service to enable retailers and other trade buyers to check their wholesaler’s URN and make sure they are approved before ordering or buying alcohol from them. The results page showing approval should be saved or printed to support the normal due diligence checks.
Businesses will not need to check all their suppliers on 1 April 2017 they can carry out checks before they next trade with each wholesaler. They will need to repeat this check periodically, to ensure their wholesalers remain approved for AWRS. Keep records of the checks as evidence of your due diligence activities.
When you need to apply
You’ll need to apply for AWRS if all the following apply:
- your business sells, or arranges the sale of alcohol, and has an establishment in the UK
- your sales are made at, or after, the point where Excise Duty is due
- any sales to other businesses are made for onward sale or supply
Types of business that need to be approved
All businesses that supply alcohol to other businesses for resale need to apply. This includes:
- breweries and microbreweries
- wine producers and vineyards
- spirit producers
- cider producers who make more than 70 hectolitres of cider a year
- wine importers
- general wholesalers selling alcohol, including cash and carry businesses
- specialist wine wholesalers
You’ll also have to apply if you’re supplying alcohol to other businesses for resale as one of the following:
- a broker
- a retailer who makes regular sales to other businesses
- an auctioneer
- a charity, non-profit organisation or educational establishment that produces and/or supplies alcohol to other businesses for resale
Excise Notice 2002 section 3 has more information about the scheme and types of businesses likely to be affected.
Businesses that where already operating in alcohol wholesale prior to 1 April 2016
These businesses should already have applied for approval. If you haven’t yet applied do so now.
Businesses new to alcohol wholesaling from 1 April 2016
You can apply for approval as a
- limited company
- sole trader/self-employed
- business partnership
- limited liability partnership
- limited partnership
As a new business, you may have to provide additional information after applying. You would usually supply this during your site visit and it would include:
- your business plan
- letters of intent from:
- suppliers and customers
- third party distribution companies
If you work for yourself you must first have registered for Self Assessment and enrolled for the online service.
Your agent or accountant will still be able to submit your Self Assessment Return if you’ve authorised them to do so.
Once registered for Self Assessment, you can then apply for approval in AWRS. You mustn’t begin trading in alcohol wholesaling until approval is given.
Exclusions to the scheme
You don’t need to apply for approval for AWRS if you’re a trader who’s mainly a retailer and you’re covered by the exemption.
This exemption applies if you’re an authorised retailer, with a retail licence, who doesn’t set out to make sales of alcohol to other businesses and you:
- only make wholesale sales that take place unintentionally in the course of your retail activity and without your prior knowledge (like unplanned sales through a supermarket checkout)
- knowingly make wholesale sales but they’re uninvited by you and only on an exceptional basis (perhaps the village fete once a year)
This can happen if you don’t know the buyer and the only indication you might have that the purchase is being made for commercial purposes is if a tax invoice is requested.
These are known as ‘incidental sales’.
Corporate group sales
Wholesale sales of alcohol between members of the same corporate group are excluded from the scheme. There’s no need to apply for approval for AWRS.
If wholesale sales are made outside of the corporate group, the companies involved will need to apply for approval.
If more than one company from the same group makes wholesale sales, those companies can apply for group AWRS approval.
Excise Notice 2002 section 14 gives further information about group approvals.
Apply for approval
If you were operating in alcohol wholesaling prior to 1 April 2016 you should have already applied online for approval. If you haven’t, then you must apply now.
If you intend to start wholesaling in alcohol you must apply for approval at least 45 days before you intend to trade. New businesses should ensure that they have sufficient business planning in place for HMRC to be able to test they meet our Fit and Proper criteria before making their application (Excise Notice 2002, section 6 contains more information). You must wait until you get approval from HMRC before you start trading.
You’ll need to use the same Government Gateway username and password that you used to make your initial application. You can then view the status of your request or make amendments.
If your application is being processed
You can make any necessary changes or correct errors in the information you supplied. You should do this as soon as possible, following the instructions for ‘making changes’.
Sign into the service to make changes.
If you’ve been approved by HMRC and received your AWRS URN
You’ll need to tell HMRC about any changes to your details as soon as possible.
HMRC must be notified of some changes no later than 14 days from the date of change, including changes to:
- phone numbers
- email address
- trading name
- VAT number
Tell HMRC about any change of address for your principal place of business or to any of your trading premises before you use the new premises.
Excise Notice 2002 paragraph 10.4 has a full list of changes and the circumstances where you need to immediately inform HMRC.
Sign in to the service to make changes.
Cancelling or withdrawing your approval
If your AWRS application has been approved by HMRC but you decide to cancel it, you must let us know at least 30 days before the date you intend to stop trading in alcohol.
You should make arrangements to dispose of any wholesale alcohol stock before this date.
If your application hasn’t been approved you can withdraw an application where you’ve, for example:
- applied in error
- signed up as the wrong business type
- stopped trading
Sign in to the service to cancel or withdraw your AWRS approval.
New criminal and civil sanctions have been introduced for both wholesalers and trade buyers found buying alcohol from non-approved wholesalers.
Any alcohol found on the premises of unapproved businesses may be seized, whether or not the duty has been paid.
Businesses will have a similar right to review and appeal as they do for other HMRC regimes for any civil penalties raised, or decisions related to their approval.