The UK warehousing sector is set for a significant regulatory shift in 2025, as the government simplifies the rules surrounding the storage of excise goods. These changes involve the repeal of certain requirements under the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 (WOWGR), alongside a renewed emphasis on the Excise Warehousing (Etc.) Regulations 1988 (EWER).
What Are WOWGR and EWER?
WOWGR was introduced in 1999 to strengthen oversight of excise goods stored in UK warehouses. It required warehousekeepers to ensure that owners of goods, particularly alcohol and tobacco, were registered with HMRC. This applied to both UK and non-UK businesses and was aimed at preventing excise fraud.
EWER, meanwhile, has long been the backbone of excise warehousing law. It governs the operation of approved warehouses, allowing excise duty to be suspended until goods leave the warehouse for consumption or export. Under EWER, warehousekeepers must maintain accurate records of goods and their owners, providing the foundation for accountability in the excise supply chain.
What’s Changing?
From 3rd March 2025, the UK government will repeal the WOWGR requirement for owners of goods to register with HMRC and abolish the need for non-UK businesses to appoint Duty Representatives.
- Immediate Impact on Applications:
Effective immediately, HMRC has stopped processing new applications to register as an Owner of Goods and Duty Representatives. However, ongoing applications will still be processed. Forms related to these registrations (EX60, EX60A, EX64) remain accessible on GOV.UK, but it is expected that they will be removed when the changes come into effect on 3rd March 2025.
- Warehousekeepers’ Responsibilities:
Although the WOWGR owner registration requirement is ending, warehousekeepers must still record the owners of goods stored in their facilities and perform due diligence on these owners and their supply chains. This remains a core responsibility under EWER.
- Duty Representatives:
Duty Representatives will no longer act on behalf of non-UK owners of goods. These owners will still be able to deposit duty-suspended goods in UK excise warehouses without needing a representative.
The full list of future amendments are available here.
What Does This Mean for Businesses?
HMRC has assured the sector that these changes should not introduce additional burdens. Due diligence checks will remain part of the standard operational requirements under EWER, ensuring that warehousekeepers maintain oversight of stored goods without the need for WOWGR-related processes.
That said, some in the sector have expressed concerns that excessive compliance demands from HMRC might creep in, particularly around due diligence obligations. UKWA will continue to monitor developments and relay any information around this important issue to our members. For more details, please consult HMRC’s guidance here.