HMRC abolishes WOWGR Registration requirement for excise goods stored in duty suspense

This update means several significant changes for companies handling excise goods in the UK. Here’s a breakdown of the key points:

1. Abolition of WOWGR Registration Requirement:

   • Effective Date: From 3 March 2025, companies no longer need HMRC approval (WOWGR registration) to store excise goods in duty suspense.

   • New Applications: HMRC is no longer accepting new WOWGR applications.

2. Changes to Storage Time Limits:

   • Previously, if a company wasn’t WOWGR-registered, there was a 72-hour limit for storing goods in duty suspense.

   • With the abolition of the WOWGR requirement, this 72-hour restriction is removed, allowing more flexibility for companies storing excise goods in duty suspense.

3. Implications for Non-UK Companies:

   • Non-UK companies will no longer be required to obtain prior HMRC approval to store excise goods in duty suspense.

   • They also do not need to appoint a Duty Representative to handle the payment of duty on their behalf (although many may continue to do so if they do not have their own deferment facilities).

4. SEED Database Changes:

   • Owners of warehoused goods will no longer be included in the UK SEED database.

   • Due Diligence Requirement: Warehousekeepers still have the responsibility to perform due diligence on companies depositing excise goods into duty suspense.

What This Means in Practice

• Operational Flexibility: Companies, especially non-UK entities, will find it easier to store excise goods in duty suspense without the previous administrative burden of obtaining HMRC approval.

• Duty Management: Even though appointing a Duty Representative is no longer a necessity, companies may choose to do so if they haven’t established their own systems (such as deferment facilities) to manage duty payments.

• Due Diligence Remains Crucial: Despite the relaxed requirements for companies, warehousekeepers must continue to verify the credentials and compliance of companies wishing to store goods in duty suspense.

Overall, these changes are aimed at streamlining the process and reducing administrative burdens while still ensuring that appropriate controls and due diligence measures remain in place within the supply chain.