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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and Sanctions: Buying from an unapproved wholesaler - what does not count as buying from an unapproved wholesaler?

In most cases it will be clear whether or not a person has purchased alcohol for re-sale from an unapproved wholesaler.

Sales from an approved wholesaler to an unapproved wholesaler do not attract a behavioural penalty. This scenario calls into question the fit and proper status of the approved wholesaler. The unapproved wholesaler may be liable to a ‘trading without approval’ penalty if the wholesaler is making wholesale sales.

AWRS20800 sets out exclusions from the scheme. Examples include:

  • Where a person purchases alcohol for re-sale from a licenced retailer and the retailer does not trade with an intention to make wholesale sales. Usually these sales will be made unknowingly or unintentionally.


  • Purchases from an unapproved wholesaler where the wholesaler and the purchaser are a part of the same corporate group.


  • Purchases from wholesalers who are not established in the UK.


  • Purchases made before the requirement to only purchase alcohol for re-sale from approved businesses (1 April 2017)