UK only - HMRC + AWRS

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Ray Blockley

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Feb 13, 2017, 9:41:37 AM2/13/17
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Hi all,

Apologies if this is repetition from many months back, but.......

After chatting with Jez about this, I'm throwing this up here in case anyone else is confused - or as in my case, has a very confused specialist beer shop I supply a few times a year, now insisting that I MUST have an AWRS number to pass on to them or they will not buy anything from me & indeed will report me...

As a sub-70HL cidermaker - but fully registered & inspected by Uncle Tom Cobley & all & his sister & nephew... - according to this link and the following statement, I do not need to be registered under AWRS (if I'm interpreting this correctly!):

"Types of business that need to register

All businesses that supply alcohol to other businesses for resale need to apply. This includes:
  • breweries and microbreweries
  • wine producers and vineyards
  • spirit producers
  • cider producers who make more than 70 hectolitres of cider a year
  • wine importers
  • general wholesalers selling alcohol, including cash and carry businesses
  • specialist wine wholesalers"
 Link: https://www.gov.uk/guidance/the-alcohol-wholesaler-registration-scheme-awrs

This old PDF also seems to support that the smaller none-duty paying sub-70HL cidermaker is also excluded from the AWRS:

As does this simplified breakdown: 


So the way I view this is:
1. I do not and have never made more than 70HL pa. 
2. I do not act as a wholesaler in that I do not "buy in" any type of alcohol to "sell on". 

I'd be very grateful if anyone KNOWS DIFFERENTLY (NB not "thinks differently") to let me know ASAP...? 

Much of the HMRC stuff as usual is bloody confusing & often seems contradictory too. Or maybe it's just my age.... 

Thanks. 

Ray. 

alistairphillips

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Feb 13, 2017, 10:05:19 AM2/13/17
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We registered with AWRS, I received a call after a month or so from HMRC to ask me to log back into the system and withdraw the application because we didnt need to, due to the amount we produce being under the 70HL.

We received a letter from HRMC confirming the withdrawal of our application, and a reminder to reregister in future if we surpass the 70HL limit 

Alistair

Tim

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Feb 13, 2017, 10:22:57 AM2/13/17
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Does not affect you Ray, that I can assure you of. I would have been exempt if it were not for the other stuff I buy in and sell on.

 

Tim in Dorset

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Raglan Cider Mill

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Feb 13, 2017, 12:02:35 PM2/13/17
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I understand that some CAMRA festivals are going to be asking for a copy of your HMRC exemption letter if you do not have an AWRS number because you don’t need to register, maybe this is what you need to offer this shop.  Like Alistair I was asked by HMRC to withdraw my application for being sub 70HL.

Sally

 

From: cider-w...@googlegroups.com [mailto:cider-w...@googlegroups.com] On Behalf Of Ray Blockley
Sent: 13 February 2017 14:42
To: Cider Workshop <cider-w...@googlegroups.com>
Subject: [Cider Workshop] UK only - HMRC + AWRS

 

Hi all,

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Ray Blockley

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Feb 13, 2017, 12:29:30 PM2/13/17
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Thanks Sally & Tim, plus those who have replied directly off group. 

A bit more fact finding & checking to do methinks... I think I'm OK but I don't want a fine / penalty / prosecution so I'd sooner be told to withdraw an application than get caught out... 

Will report back what I find out & what happens. 

Ray.   

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Vince Wakefield

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Feb 13, 2017, 1:03:29 PM2/13/17
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You are correct, I had to withdraw my application as I don’t pay duty, I can’t be registered and have a letter from HMRC saying just that,

 

To be honest it is another dogs dinner, on one hand they are telling retailers not to buy from anyone without a number and on the other not allowing us to register.

 

 

Vince

Rutts Lane Cider

www.ruttslanecider.co.uk

vi...@ruttslanecider.co.uk

 

 

 

From: cider-w...@googlegroups.com [mailto:cider-w...@googlegroups.com] On Behalf Of Ray Blockley
Sent: 13 February 2017 14:42
To: Cider Workshop
Subject: [Cider Workshop] UK only - HMRC + AWRS

 

Hi all,

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Vince Wakefield

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Feb 13, 2017, 1:09:25 PM2/13/17
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This may help, from https://www.gov.uk/government/publications/excise-notice-2002-alcohol-wholesaler-registration-scheme/excise-notice-2002-alcohol-wholesaler-registration-scheme#exclusions

 

5.1 Circumstances where sales are outside the scope of the scheme

AWRS only applies to alcoholic liquor that has been charged with excise duty and, with the exception of the situation explained in paragraph 3.7, is sold at, or after, the duty point.

Any alcoholic liquor that has been exempted from excise duty, granted a specific duty relief or is duty free is not caught by this scheme. Examples include:

From: cider-w...@googlegroups.com [mailto:cider-w...@googlegroups.com] On Behalf Of Ray Blockley
Sent: 13 February 2017 17:29
To: Cider Workshop
Subject: Re: [Cider Workshop] UK only - HMRC + AWRS

 

Thanks Sally & Tim, plus those who have replied directly off group. 

 

A bit more fact finding & checking to do methinks... I think I'm OK but I don't want a fine / penalty / prosecution so I'd sooner be told to withdraw an application than get caught out... 

 

Will report back what I find out & what happens. 

 

Ray.   

On Mon, Feb 13, 2017 at 5:01 PM, Raglan Cider Mill <in...@raglancidermill.com> wrote:

I understand that some CAMRA festivals are going to be asking for a copy of your HMRC exemption letter if you do not have an AWRS number because you don’t need to register, maybe this is what you need to offer this shop.  Like Alistair I was asked by HMRC to withdraw my application for being sub 70HL.

Sally

 

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Ray Blockley

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Feb 13, 2017, 1:14:21 PM2/13/17
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Thanks Vince, yes I'd read that part which made me fairly confident I was OK.. I guess I was brought up "Belts & Braces" wise... ;-) 

Ray. 

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Kniveton Cider Company

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Feb 13, 2017, 5:40:39 PM2/13/17
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Ray
We went through the application/withdrawal process. During the
discussion with HMRC, I asked about the "What if a customer asked"
scenario and was told to point them towards bit on their web-site and if
they were still concerned to phone the HMRC help-line - fair enough.

But.... a quick google shows plenty of web-sites advising pubs, clubs
and retailers that EVERY wholesaler MUST have an AWRS and the penalties
they face for not checking could mean stock could be seized and they
could end up in jail.

Some people are going to take a lot of convincing

Kevin Woolley Kniveton Cider Company

Ray Blockley

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Feb 16, 2017, 10:42:09 AM2/16/17
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Just to cross T's & dot I's... 

After emailing CITEX for confirmation (just so I can be fully assured - the folk at the beer shop got me worried they knew something that we & I didn't...), got a phone call today from a very nice chap from CITEX in Glasgow confirming that no cidermaker producing under 7000L & therefore not paying duty, has to register for AWRS. 

So again, thanks to everyone on and off list for your help & responses. 

Cheers, Ray.    

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