HM Revenue and Customs introduced the Alcohol Wholesaler Registration Scheme in 2015 to tackle alcohol fraud and from the 1st of April 2017 if you buy alcohol to sell from a UK wholesaler, you’ll need to check that the wholesaler has registered with HMRC and has an AWRS Unique Reference Number.
Trade buyers and wholesalers will be able to use an online look-up service of approved wholesalers to check that the wholesalers you buy from are registered.
Licensees can face penalties if they trade without checking their supplier is approved.
The types of businesses that need to register are businesses that supply alcohol to other businesses for resale including:
- cash and carries
- breweries and microbreweries
- wine producers, vineyards
- spirit producers
- cider producers who make more than 70 hectolitres of cider a year
- wine importers
- brokers
- retailers who make regular sales to other businesses
- auctioneers
- charities, non-profit organisations and educational establishments that produce and/or supply alcohol to other businesses for resale
- general wholesalers selling alcohol
- specialist wine wholesalers
There are exclusions to the scheme. You don’t need to register 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’.
New criminal and civil sanctions have been introduced for both wholesalers and trade buyers found buying alcohol from non-registered wholesalers.
Penalties for:
- wholesalers trading without having submitted their application to HMRC came into force from 1 April 2016
- trade buyers who buy alcohol from unregistered wholesalers will start from 1 April 2017
Any alcohol found on the premises of unregistered 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.