What is it?
To cut down on unlawful selling of alcohol, HMRC have brought in a scheme that requires all business who are wholesaling alcohol – business to business sales – to become registered and be issues an AWRS unique reference number (URN). It also requires trade buyers to make sure that they are purchasing from registered suppliers
When does/did it start?
The requirement for businesses to register was 1st April 2016. However, the requirement for purchases to check that their suppliers are registered is not until 1st April 2017.
What are trade buyers’ obligations?
To ensure that the purchase of alcohol is from a legitimate supplier, you should request the wholesaler’s URN and check its authenticity before you do any business with them. You should then periodically refresh these checks to ensure that the wholesaler’s approval remains valid.
Where can I check the URN numbers?
The place to check the URN numbers are on HMRC’s AWRS online look up system. However, as of time of writing, the system is not yet live.
What happens if my supplier says they are excluded from the scheme?
If your supplier has advised you that they are excluded from the scheme, you need to check that this is valid. The two main exclusions are:
- Incidental sales – if a business’ main supply is to the general public and a wholesale is unknowing or unintentionally made in the course of the day to day running of their business. For example, a supermarket or a corner shop.
- For purchases from overseas – as described. However, it would be in your interest to keep proof of the source of the goods to demonstrate that they were imported directly from an overseas supplier and that duty has been paid.
What extra things do I need to keep?
There are no extra requirements to keep extra records as a trade buyer. Other than the need to prove that you have indeed requested and check the authenticity or a wholesalers URN.
What happens if I don’t abide by these new laws?
If a business is found to be selling as or purchasing from an unauthorised wholesaler, then they could be facing a fine of up to £10,000, up to 7 years in jail or both
For more details on who needs to be registered and who is excluded, please go here: https://www.gov.uk/guidance/the-alcohol-wholesaler-registration-scheme-awrs
For more details on the trade buyers’ obligations, please go here: https://www.gov.uk/government/publications/excise-notice-2002-alcohol-wholesaler-registration-scheme/excise-notice-2002-alcohol-wholesaler-registration-scheme#trade-buyers-obligations