The scheme: importers and overseas businesses
The AWRS does not extend beyond the boundaries of the UK, except in respect of the Isle of Man, which has adopted an identical scheme and whose wholesalers will appear on our register.
To import alcohol commercially to the UK from another EU country, a business must use one of the recognised schemes, for example, import to a tax warehouse or use the Registered Consignee scheme (for duty suspended goods), or use one of the duty paid schemes to import goods that have been duty paid in another EU Member State. Third country imports are covered under the provisions of the Community Customs Code.
These schemes cover imports into the UK, therefore anyone responsible for importing alcohol from the EU, either duty suspended or duty paid in another EU member state, should in the majority of cases be known to HMRC and will have documentation confirming the duty paid status of the goods. The majority must have an excise registration or will have been required to pay UK duty upfront before the goods are moved. Identifying the wholesaler in these cases is reasonably straightforward should these businesses then supply UK duty paid alcohol to another business.
There are, however, situations where a business may import for their own use, for example, a business importing wine from Italy and paying the duty on their own duty account. In these circumstances, there is no intermediary in the UK as the wholesaler is actually based abroad. You must check that the buyers in these cases hold evidence as to the provenance of the goods and of duty payment to assure you that the product was sourced directly from an overseas supplier and that UK duty has been accounted for.
Types of evidence include:
- a purchase invoice, and
- copies or details of the relevant HMRC document to prove duty payment, for example, forms HM2, HM4, TRC2 and so on.