Brewers and packagers of beer may produce, hold and move beer in duty suspension between registered brewery and packaging premises and excise warehouses approved to receive beer. In addition, registered brewers and packagers may import beer in excise duty suspension from the EC and elsewhere and export directly from registered premises.
Information on who must apply to be registered, when to register and how to register can be found in sections 3, 4 and 5 of Notice 226 Beer Duty.
The registration of a brewer or packager’s premises by HMRC makes them a ‘tax warehouse’ without the need for a separate approval. ‘Tax warehouse’ is a term adopted by the EU to describe any premises approved for the production, holding and movement of excise goods.
The sections of ALDA that relate to the registration of producers and packagers of beer (registration to hold beer in duty suspense) are sections 47 and 41A. The regulations relating to registration of producers of beer are contained in Part II of the Beer Regulations 1993, regulations 5, 6 and 7 and those relating to registration for duty suspension in Part IV, regulations 9, 10 and 11.
To note. A brewer must also register for the Alcohol Wholesaler Registration Scheme (AWRS) if they sell duty paid alcohol to another business. It is the responsibility of any business who purchases alcohol for onward sale or supply to check that the wholesaler they purchase from has been approved by HMRC. Therefore, any business purchasing beer from a brewer should check that the brewer has been approved as an alcohol wholesaler under AWRS. Details of approval and AWRS procedures can be found in the AWRS guidance and Notice 2002: Alcohol Wholesaler Registration Scheme.