Section 24 — removal of alcoholic products from approved premises

Guidance about the procedures for approved producers removing alcoholic product from approved premises to another approved premises (including your own approved premises if you own a multi-site operation) or an excise warehouse without payment of duty.

24.1 Removals from approved premises 

Duty must generally be paid on all removals from your approved premises for the following purposes: 

  • for UK consumption (usually known as a removal to home-use) meaning the alcoholic product passes a duty point and leaves duty suspension 
  • when alcoholic products are constructively removed 

Duty must also be paid if: 

Provided you comply with conditions HMRC may impose, you may remove alcoholic products from your approved premises without payment of duty for the following purposes: 

If you send duty suspended alcoholic product to an excise warehouse for bottling, packaging or storage, you’ll need to be approved as a registered owner of warehoused goods under the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 (SI 1999/1278). You’ll find more information on this and the procedures to follow in  registration and approval of excise goods held in duty suspension (Excise Notice 196). Please note, HMRC are currently reviewing the Warehousekeepers and Owners of Warehoused Goods Regulations policy. 

24.2 Security for duty 

You’ll need financial security to guarantee the duty on alcoholic products in duty suspension for movements from Northern Ireland to an EU country. 

The guarantee must be: 

In certain circumstances, further guarantees may be required for the holding and movement of alcoholic product within the UK. For further information on guarantees, read section 8 — financial security.

24.3 Duty responsibility 

You’ll be responsible for the duty on the alcoholic product until you receive a receipt. The receiving producer with an alcoholic products producer approval (APPA) must: 

  • complete a report of receipt, if the movement is submitted through Excise Movement and Control System (EMCS)
  • sign the Alcohol Duty receipt (for example the delivery note) if under simplified procedures  

The receiving approved producer must issue a receipt within 5 days of the date of receipt of the alcoholic product in their approved premises. If you do not receive a receipt, you should contact them.  

If you fail to obtain a receipt within 4 months, you’ll be liable for the duty due on the alcoholic product. If you subsequently receive a receipt, you may credit your duty account with the appropriate amount of duty. 

When the alcoholic product is delivered to home-use from the receiving approved premises, duty will become due. Duty must be paid by the producer who finally delivers the alcoholic product to home-use. 

24.4 Excise Movement and Control System procedure and documentation required 

All intra UK movements of alcoholic products will need to be submitted through the Excise Movement and Control System (EMCS) unless they qualify for simplified procedures. For further information on EMCS, read receive goods into and remove goods from an excise warehouse (Excise Notice 197). Your approved premises under your alcoholic products producer approval (APPA) will function in the same way as an excise warehouse in relation to the receipt and dispatch of excise goods in duty suspension. 

Duty suspended and duty paid movements between Northern Ireland and EU countries will also need to be submitted through EMCS. 

Where movements of alcoholic products are under simplified procedures and involve alcoholic product moving between UK approved alcoholic product producers or excise warehouses approved to receive and store alcoholic product, ownership of the alcoholic product must remain with the alcoholic product producer during the course of the movement. Alternative documents will be suitable if they contain all these: 

  • the name and address of your approved premises 
  • a unique reference number 
  • the name and address of the approved premises you’re sending the alcoholic product 
  • the date of despatch 
  • a description of the alcoholic product, including the quantity 
  • a statement indicating that the alcoholic product is being moved in duty suspension 
  • you’ve been paid or expect to be paid in cash for the supply of alcoholic product in duty suspension (or for any service you provide in relation to alcoholic product in duty suspension), read section 10 — duty suspension 

24.5 Simplified procedures 

Simplified procedures allow for alcoholic products to move, under duty suspension arrangements, using alternative documents, either in paper or an electronic format, instead of an electronic administrative document (eAD) generated through EMCS. 

Simplified procedures apply are limited to: 

  • alcoholic products moving between producers with an alcoholic products producer approval (APPA) or excise warehouses approved to receive and store the alcoholic product — ownership of the alcoholic product must remain with the alcoholic product producer during the course of the movement 
  • movements for direct export only from the UK where the dispatching alcoholic product producer is authorised for Customs Supervised Exports, formerly Local Clearance Procedures, and can provide a full customs export declaration — movement guarantee details must be shown on the declaration — further information can be found in receive goods into and remove goods from an excise warehouse (Excise Notice 197) — Please note — movement guarantee policy is being reviewed by HMRC

If movements do not meet the above criteria, then it will be necessary to use EMCS. 

If the movement is under simplified procedures and involves alcoholic product moving between approved premises or excise warehouses approved to receive and store the alcoholic product, alternative documents will be suitable if they contain: 

  • a unique reference number 
  • your name and address 
  • the name and address of the consignee 
  • the destination address 
  • a statement that the alcoholic product is in duty suspension 
  • the description of the alcoholic product (that is, product name), the quantity contained in each package (and if appropriate, the capacity of each container), alcoholic strength, package size and date of dispatch from your approved premises 

You must keep a copy of the despatch document, and the warehouse keeper’s receipt, for your own records.  

For more details on the procedures for inter-warehouse removals, read receive goods into and remove goods from an excise warehouse (Excise Notice 197).