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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Trade buyers: trade buyer's obligations

From 1 April 2017, it is an offence to buy controlled liquor that is intended for re-sale from unapproved UK wholesalers, unless the sale is excluded from the scheme (for example it is an incidental sale).

The AWRS does not introduce any new legal requirements for trade buyers who are not also approved wholesalers. However, they can be guilty of an offence/liable to a civil penalty for buying from an unapproved wholesaler. As a result they must be able to demonstrate to you that they have checked that the UK wholesalers they purchase from have been approved by HMRC (or have alternative evidence to show they have bought from a retailer who legitimately does not need to be approved).

They do this by requesting the AWRS URN of the wholesaler they are buying from and checking that it is valid via the online look-up system (accessed via the Government Gateway). The online look up service will hold details of all current approved and ceased wholesalers. Where an approved wholesaler has ceased trading, it will return the date that the wholesaler’s approval ceased.

The look-up service returns a page showing the business name with Approved or no longer approved underneath. Details on the page include:

  • the AWRS status
  • AWRS registration number
  • Effective date of registration
  • Business name
  • Trading name
  • Principle place of business

The date and time of the search are also shown on the page.

For searches where the AWRS approved business is a part of a group the page lists the group members, shows the above information for the representative member and the following details for each group member:

  • Business name
  • Trading name
  • Principle place of business

Where a business has been revoked or its approval has ceased, for example because it has stopped wholesaling, the page will also show an end of registration date.

A trade buyer will be expected to check a wholesaler’s approval status before trading with them. They will also be expected to periodically check that the wholesaler is still approved. We do not prescribe how often the check should be made, this will be up to the business to risk assess how often they think they should check each supplier’s AWRS status.

We also recommend that trade buyers carry out similar types of due diligence checks that approved wholesalers must carry out to satisfy themselves of the legitimate provenance of the goods. Examples of reasonable checks are in Section 13 of Notice 2002.  Further information on the due diligence condition is in AWRS60600 and Excise Due Diligence Condition guidance.

Guidance on when a trade buyer can purchase from a business not approved to wholesale is also in Section 13 of Notice 2002.