Alcohol Wholesaler Registration Scheme – 7 weeks to register!

February 05, 2016

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To combat duty evasion on alcoholic beverages, HMRC has introduced the Alcohol Wholesaler Registration Scheme (“AWRS”) from 1 January 2016. Following consultation, details of the scheme have now been published in the Finance Bill 2015 and subsequently HMRC Notice 2002. Please use the following link to see full details of the Notice.

https://www.gov.uk/government/publications/excise-notice-2002-alcohol-wholesaler-registration-scheme/excise-notice-2002-alcohol-wholesaler-registration-scheme#wholesalers---conditions-and-restrictions

What does it mean?

A UK business which either sells or arranges the sale of alcohol at or after the excise duty point (i.e. duty paid alcohol goods) to other businesses for onward sale or supply, and the business is not primarily a retailer to the public, must register for the AWRS before the 31st of March 2016.

Failure to register will result in a behavioural penalty of up to £10,000, regulatory penalties of £500 per unregistered sale, potential seizure of the alcohol goods and cessation of your ability to trade in duty paid alcohol in the UK!

In addition, in order to qualify for approval under the AWRS, a business must have reviewed their supply chain to evidence they are only purchasing duty paid alcohol from legitimate suppliers and have in place a documented due diligence policy that its employees are following daily to prevent the purchase of illicit (duty unpaid) alcohol.  HMRC will vet the application as part of the process.

From 1 April 2017, it will be a criminal offence to purchase duty paid alcohol wholesale from a business that is not registered under the AWRS scheme.

What can you do now?

Evaluate your current supply chain and also design or enhance your current due diligence procedures in anticipation of your AWRS application.

For further details please contact me or Matthew Clark, Head of PwC's Customs, Exercise and international trade network, direct line: 07718 339388 ,

Email: [email protected]  

or Haider Hatteea, Senior Manager within PwC’s Customs, Excise and International Trade network, direct line: (0)118 938 3088 Email: [email protected]

Christine O'Malley

e: [email protected]

p: +44 (0)16 1245 2429