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Guidance

Submit an undertaking for Scotch Whisky

Submit an undertaking to HMRC covering the movement of Scotch Whisky outside of Scotland.

Who needs to submit an undertaking

You must submit an undertaking if you’ve registered for the Spirit Drinks Verification Scheme or applied for bulk importer verification and:

  • are involved in bulk movement of Scotch Whisky outside Scotland
  • blend, bottle and label or label only Scotch Whisky outside of Scotland

The undertaking will be valid for 2 years. You will need to reapply once the 2 years are up.

Who does not need to submit an undertaking

You do not need to submit an undertaking if you’re importing Scotch Whisky to use in products that are not alcoholic beverages.

What you need to agree to do for an undertaking

As part of the undertaking you must agree to:

  • comply with the product specification for Scotch Whisky in accordance with Regulation (EU) No 2019/787, or any successor regulation, relating to the definition, description, presentation, labelling and verification of Scotch Whisky 
  • keep a sample of each bulk consignment of Scotch Whisky received for 2 years 
  • notify us of the brand names to be used when selling the final product as Scotch Whisky 
  • make sure that any drink other than Scotch Whisky, produced which contains Scotch Whisky as an ingredient, is not labelled or sold in a way which creates confusion as to whether it is Scotch Whisky 
  • provide us with samples of the labels of any Scotch Whisky bottled 
  • keep records of each supplier of a bulk consignment of Scotch Whisky for 6 years 
  • keep records of each disposal of a bulk consignment of Scotch Whisky received for 6 years, and provide us or any enforcement authority with the records whenever requested 
  • you must provide us with copies of any records referenced in this undertaking if requested
  • only supply the Scotch Whisky you have received to another blender, bottler or bulk importer whose details have been published by HMRC, unless the Scotch Whisky is in a bottle (made of an inert material) that is labelled for retail sale

Read Scotch Whisky verification checklist (PDF, 282 KB, 18 pages) for the full legal wording of the undertaking.

What you’ll need

You’ll need to tell us:

  • the name of the owner carrying out the production process (blending or bottling and labelling) or the bulk importer
  • your email address and telephone number

Submit an undertaking

Submit now

After you have applied

If you need to change your details, email the Spirit Drinks Verification Unit at enquiries.sdvs@hmrc.gov.uk.

If you have any queries about your undertaking, or would like further advice, email the Spirit Drinks Verification Unit at enquiries.sdvs@hmrc.gov.uk.

Updates to this page

Published 29 May 2026

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