WOWGR Requirements

WOWGR Requirements are to be removed from law which will take effect on 3 March 2024

On 22nd January 2025 HMRC provided the following official notification
WOWGR reforms

From 3 March 2025 the following will no longer apply:

• registration of owners/Duty Representatives requirements.

• the 72 Hour Rule duty point (This removes the previous policy that revenue traders may only store goods in an excise warehouse for longer than 72 hours if they were an authorised warehousekeeper, a registered owner or they appointed a duty representative. )

Removing the duty points addresses the unintended non-compliance which was caused by the rules and associated bureaucracy and simplifies requirements making them easier for business to follow.

Latest Update 27/01/2025

Update on 27/01/2025 from HMRC….

We are writing to you in respect of the Alcohol Tobacco Warehousing Declaration (ATWD). This follows publication of The Excise Duties (Miscellaneous Amendments and Revocations) Regulations 2024 on 2 December which makes amendments to The d and Owners of Warehoused Goods Regulations (WOWGR) 1999 and comes into force on the 3 March 2025.

This concerns the following warrants:

• W1 – Excise Warehouse Return

• W5 – Alcohol Remittance Warrant

• W5D – Alcohol Deferment Warrant

• W6 – Tobacco Remittance Warrant

• W6D – Tobacco Deferment Warrant

As you may be aware the above forms have the following proprietor options:

• WOWGR Registered

• Non WOWGR VAT Registered Proprietor

• Individual Proprietor with no registration

• Proprietor is Warehousekeeper

HMRC regret to inform you that due to various circumstances out of our control, we are not able make the necessary changes to our IT systems to take account of the upcoming changes on 3 March 2025 for WOWGR repeal.

The attached paper sets out the actions to take in the short/medium term and HMRC’s long term plans.

We apologise for any inconvenience this may cause, and should you have any concerns about this matter please email holding.movement@hmrc.gov.uk Businesses who hold a Registered Owners approval on 2025 and we will reply to your query ASAP.

Software Developers action to take re: ATWD Warrants concerning Registered Owners

Short/Medium Term Actions

Businesses who hold a Registered Owners approval on or before 3 March 2025 should continue to submit warrants using the WOWGR Registered option, as they have done previously.  They should not change how they currently submit warrants, even though these approvals will no longer apply. This is to ensure that the validation within ATWD system continues to operate, and warrants are not rejected.

Similarly, when completing the W1 (Excise Warehouse Return) please continue to record ‘owner’ details. On and after the 3 March, businesses should ignore the duty representative fields as duty representatives will no longer exist. Registered Owners will also no longer exist, however, warehousekeepers must continue to identify and record the commercial owner of goods held in their excise warehouses to support the existing due diligence requirements.

Long term plans

HMRC will work with our IT providers on a permanent fix for removing the WOWGR functionality and associated validation, which will include deregistration on HMRC systems such as SEED.  We will provide further communications in due course and will ensure you are provided with the time required to make any system changes. As per above, until further notice, please continue to complete the WOWGR Registered Option for existing WOWGR registered proprietors.

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Duty Stamps

Duty Stamps requirements are to be abolished on 1 May 2025

On 22nd January 2025 HMRC provided the following official notification

Alcohol duty stamps

 The alcohol duty stamps scheme is ending from 1 May 2025. 

• From this date, the stamps scheme will no longer apply to retail containers currently within its rules (typically larger bottles of stronger spirits).

• HMRC published a paper following the announcement of the scheme’s end at budget which explains why  End of the Alcohol Duty Stamps Scheme - GOV.UK

• There will be further practical guidance published to help traders with implementing the scheme’s end later this year. 

Movement Guarantees

Removal of Movement Guarantee (Proposed)

Further details on changes will be posted here during 2025 once the exact changes are known and whether there are any interim changes required, even if both remain within the system their impact on their respective change dates will have minimal effect on operations.