Guidance

Responsibilities of excise warehousekeepers and owners of goods

Find out about checks you need to carry out before accepting goods into your excise warehouse and your obligations when receiving cash payments for duty-suspended sales of alcoholic products.

Accepting goods into a warehouse

If you’re an excise warehousekeeper, before you accept goods into your warehouse, you must make sure that you carry out appropriate due diligence checks on your customers and supply chains.

Read section 10 of registration and approval of excise goods held in duty suspension (Excise Notice 196) for more information on due diligence.

You’ll need to hold an alcoholic products producer approval (APPA) to store and move alcoholic products in duty suspension in an excise warehouse or other premises approved by HMRC.

Report cash payments for alcohol sales

Owners who have been paid, or expect to be paid in cash for alcoholic products in duty-suspension exceeding £9,000 (or equivalent in other currencies) must immediately notify HMRC of cash payments for alcohol in duty suspension (W7). Alcoholic products are spirits and spirits-based beverages, like:

  • beer
  • wine
  • cider and perry
  • other fermented products

Where duty-suspended alcoholic products are transferred to approved excise warehouses in the UK or EU member states, the form Notify HMRC of cash payments for alcohol in duty suspension (W7) must be submitted before the goods are removed from the dispatching warehouse.

Sometimes customers pay cash in 2 or more instalments which individually are below the £9,000 notification threshold, but the total sale will exceed this amount. In these circumstances approved alcoholic products producers must notify HMRC on form Notify HMRC of cash payments for alcohol in duty suspension (W7) when the first cash payment is received.

If you do not notify these type of transactions to HMRC you may receive a financial penalty.

Responsibility to pay duty

The following is a summary of the main duty points.

Circumstances Duty point Liability of warehousekeeper
A warehousekeeper accepts goods contrary to any conditions shown on their certificate of registration or approval letter. Time of deposit Sole
Goods remain in a warehouse after the authorisation ceases. Time when authorisation ceases Sole

The warehousekeeper may immediately abandon the goods to the Commissioners — further information in Notice 197.

Updates to this page

Published 23 October 2014
Last updated 3 March 2025 show all updates
  1. Information about checking registration certificates has been removed. The 'Responsibility to pay duty' section has been updated.

  2. Information about alcoholic products producer approval (APPA) has been added.

  3. First published.

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