Section 4 — approvals
Source: gov.uk (2025-11-18)

Information on how and when to apply for approval as a new alcoholic products producer and the information you must provide as part of your approval to prove that you are fit and proper.

4.1 General information

From 1 February 2025, all producers of alcoholic products are required to hold an alcoholic products producer approval (APPA).

If you are producing alcoholic products, or carrying out activities on alcoholic products which changes their alcohol by volume, product classification or produces an alternative product, you may now be considered as an alcoholic products producer and must hold an APPA. Importing finished alcoholic products, solely holding and storing third party goods or bottling bulk product without altering it is not classified as production. For more information on what is classified as production, read section 3 — production of alcoholic products (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-3-production-of-alcoholic-products).

You must first be approved as an alcoholic products producer before you start producing alcoholic products on your approved premises. The proprietor, partnership or company intending to produce alcoholic products must apply for approval.

If you are an approved producer, any alcoholic product you produce for your own domestic consumption will be liable for Alcohol Duty.

For more information about whether you require an approval and how to apply read:
- Check if you need an alcoholic products producer approval (APPA) (https://www.gov.uk/guidance/check-if-you-need-an-alcoholic-products-producer-approval-appa)
- Apply for an alcoholic products producer approval (APPA) (https://www.gov.uk/guidance/apply-for-an-alcoholic-products-producer-approval-appa)
4.2 Exemption from applying for approval

You are exempt from the requirement to apply for approval as a producer if you:
- only produce alcoholic products (excluding spirits) that are for your own domestic use
- only produce alcoholic products for research purposes or experiments into the production of alcoholic products
4.3 Approval for packagers

If you only package but do not produce alcoholic product (that is, you put bulk alcoholic product produced elsewhere into containers) you do not require, and will not be approved for, an APPA. You will be required to hold an excise warehouse approval if you want to package the product in duty suspension. For more information read receive goods into and remove goods from an excise warehouse (Excise Notice 197) (https://www.gov.uk/guidance/receive-goods-into-and-remove-goods-from-an-excise-warehouse-excise-notice-197).

4.4 Alcoholic products producer approval (APPA)

When you need an APPA

An APPA applies to those who intend to produce a type of alcoholic product (beer, cider, wine, spirits or other fermented products). For further information and whether your activities are classified as production, read section 3 – production (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-3-production-of-alcoholic-products).

You do not require an APPA if you do not produce alcoholic products and only intend to hold alcoholic products in duty suspension. In this case you will require an excise warehouse approval. For more information read receive goods into and remove goods from an excise warehouse (Excise Notice 197) (https://www.gov.uk/guidance/receive-goods-into-and-remove-goods-from-an-excise-warehouse-excise-notice-197).

What is included in an alcoholic products producer approval (APPA)

An APPA will authorise you to produce the alcoholic products you hold approval for on your approved premises. It will also authorise you to hold in duty suspension the alcoholic products you have produced on your approved premises.

Approved premises are any premises in respect of which an approved person holds an APPA and are considered a tax warehouse for the purposes of excise legislation.

Alongside production and holding the alcoholic products you have produced in duty suspension, the APPA may also authorise you to:

carry out activities on the alcoholic products you’re approved to hold in duty suspension on your approved premises — this may include blending, maturation, packaging (including canning and bottling) aeration and pasteurisation, among others

move duty suspended alcoholic products to other appropriately approved UK excise warehouses or approved premises — for Northern Ireland based producers, you can also remove duty suspended products to appropriately approved EU warehouses

receive and hold alcoholic products produced elsewhere in duty suspense and import alcoholic products directly to your approved premises

An APPA does not automatically permit you to produce all alcoholic products or carry out all of these activities. Your approval does not allow you to receive other types of alcoholic product, which you are not approved to receive. To produce an alcoholic product or carry out an activity you will need the necessary approval under your APPA.

Your APPA may cover multiple premises and categories of alcoholic products. In addition to production premises, HMRC may authorise premises, approved under your APPA, to hold alcoholic products in duty suspension, including alcoholic products produced elsewhere. There are no restrictions on where these premises can be located in relation to the distance from the production premises.

4.4.1 Non-production premises

For multi-site businesses, non-production premises can be included under the APPA if there is at least one production site on the APPA. Sites where there is no production can remain outside of the APPA and can be covered by other warehousing approvals and the obligations attached with them.

4.5 Excise warehouses and the alcoholic products producer approval (APPA)

From 1 February 2025, there is no requirement for producers to operate an excise warehouse alongside their APPA. This is because producers will be able to keep goods in duty suspension on their approved premises instead. This does not apply to importers or producers based overseas.

Under APPA producers can be authorised to produce and hold alcoholic products in duty suspension on approved premises, as well as move alcoholic products in duty suspension. An APPA may also authorise producers to hold third-party produced alcoholic products in duty suspension on approved premises. For example, a producer may be authorised to produce beer, and their APPA may also cover the ability to hold cider produced elsewhere on their approved premises in duty suspension.

It is possible to hold an excise warehouse approval alongside an APPA. The introduction of APPA has not removed excise warehouse approvals from approved producers.

Producers can retain or cancel their excise warehouse approvals based on their own business need.

4.5.1 Producers holding an excise warehouse approval alongside APPA

If an alcoholic products producer with an APPA wishes to hold an excise warehouse away from their approved premises or use a third-party excise warehouse, they can do. In this case existing warehousing obligations apply for the purposes of their excise warehouse. For further information read section 5.3 (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-5-returns-and-payments).

Where producers are moving alcoholic products between their approved premises and excise warehouse they should record the details in their business records.

4.5.2 Cancelling your excise warehouse approval

Producers can cancel their excise warehouse approval where their APPA also authorises them to hold and move the same categories of alcoholic products in duty suspension.

To cancel an excise warehouse approval, you should contact HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries). You should do this at least 30 days before the date you want HMRC to cancel the approval from (cancellation date) so we can carry out the necessary checks and close down records effectively. On the date of cancellation, you must destroy your certificate of registration, or we may impose a financial penalty.

Where the approved premises and excise warehouse are at the same address, you will not need to physically transfer the duty suspended alcoholic product before the cancellation date. You must keep clear business records to show which products were held under the APPA and which under the excise warehouse, prior to the ‘transfer’.

Where the approved premises and excise warehouse are at different addresses, and the excise warehouse premises are no longer going to be part of your business, you must transfer the duty-suspended alcoholic products to their approved premises before the cancellation date, otherwise excise duty becomes due. You must record clear details in business records about this.

4.6 Types of production and the required approvals

Legacy registrations and licenses

Prior to 1 February 2025 all of your production premises required a separate registration or license under the Alcoholic Liquor Duties Act 1979. If you were registered or licensed to produce alcoholic products prior to 1 February 2025 you do not need to apply for an APPA. Your separate registrations and licenses will be migrated to a single new APPA. In February 2025 you will receive an online service letter from HMRC confirming the details of your new alcohol approval and your APPA ID.

If you have not received a letter by 25 February 2025, contact xxx@xxx.xx (mailto:xxx@xxx.xx) or write to HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries).

Compounding and rectifying

Prior to 1 February 2025, if you carried out activities on duty-suspended alcoholic products such as rendering wine or cider sparkling, or compounding (mixing) and rectifying (re-distilling) spirits, you were required to hold an excise warehouse approval, with the business authorised as an excise warehouse keeper.

This is no longer a requirement for spirits producers because an APPA will provide you with approval to produce a type of alcoholic product and hold alcoholic products in duty suspense. Your APPA can also authorise you to rectify and compound spirits in duty suspension that you do not produce. If you hold an APPA, there is no longer a requirement to perform these activities in an excise warehouse. You may wish to operate (or continue to operate) an excise warehouse, and further guidance on this can be found at registration and approval of excise goods held in duty suspension (Excise Notice 196) (https://www.gov.uk/guidance/registration-and-approval-of-excise-goods-held-in-duty-suspension-excise-notice-196).

If you operate (or continue to operate) an excise warehouse, and pay the duty due through Alcohol and Tobacco Warehousing Declarations (https://www.gov.uk/guidance/alcohol-and-tobacco-warehousing-declarations), you will still be required to submit the monthly nil Alcohol Duty return required as an approved alcoholic product producer online by the 15th day of the month.

Compounding and rectifying on cruise ships

You will only need an APPA if rectifying and compounding to produce spirits on board the cruise ship takes place in British territorial waters.

Base spirits, for use in compounding and rectifying, can be loaded onto the cruise ship duty-free as ships stores, or on drawback. Any products produced from the compounding and rectifying must also be controlled as stores onboard the vessel.

Read more about the loading of ships stores (https://www.gov.uk/government/publications/excise-notice-69a-duty-free-ships-stores/excise-notice-69a-duty-free-ships-stores#ships--loading-excise-good-as-stores-in-the-uk).

Small cider makers

Prior to 1 February 2025, cidermakers who produced less than 5 hectolitres of pure alcohol in cider and no other alcoholic products were exempt from the requirement to register for production approval. From 1 February 2025, they must now apply for an APPA with HMRC.

Examples of the required approvals

The annex in this section (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-4-approvals#section4-annex) includes examples of the required approvals for different types of production activity.

4.7 Applying for approval

When applying for approval, you should specify the alcoholic products, activities and premises you require approval for. If you intend to produce more than one type of alcoholic product, or you intend to produce at more than one premises, you should include the details of all alcoholic types you wish to produce and all the premises you wish to carry out production at in your approval application.

If you need to update your approval, such as by seeking approval to produce other alcoholic products, or your details change, read section 4.25 (#changed-details).

4.8 How to apply for approval

From 1 February 2025, alcohol producers can apply for an APPA online (https://www.gov.uk/guidance/apply-for-an-alcoholic-products-producer-approval-appa).

4.8.1 Information to be provided in the approval application

When applying for approval you will be required to provide:
- the name and address of the applicant
- information on the status of your business, for example, if you are operating as a sole trader, partnership, limited company or other status
- the addresses of the premises to be approved and where it is different, the address of the applicant
- the plan of the premises to be approved
- if applicable, the name, position in the business and contact details of the officer, employee or other person responsible for making the application on behalf of the applicant
- the unique taxpayer reference (UTR) allocated to the business and the unique taxpayer reference (UTR) of individuals for sole proprietors and partnerships
- the details of any people being or becoming connected with the applicant including their APPA ID
- the category or categories of alcoholic products produced on the premises to be approved
- the date the applicant plans to begin the production of the alcoholic products
- if you are applying for an APPA and intend to compound or rectify duty-suspended alcoholic product, you should include all of the alcohol (including the alcohol in the original base spirit) in the final alcoholic product produced
- where importing or exporting alcoholic products, the category or categories of alcoholic product to be imported or exported
- where sending or receiving alcoholic products to or from other approved persons or excise warehouses, the approval numbers assigned to that approved person or excise warehouse
You should allow plenty of time between your application for approval and when you intend to start production. We will aim to process your application within 45 working days but this may take longer if you have not provided all the information we need to make a decision.

4.8.2 How to complete the online application form

When completing the online application form, there is the option to save answers and return to the application form. The saved answers will be available for 28 days. You can also optionally provide attachments to support your application.

The online approval application form includes 3 sections.

Section 1 — business and contact details

This requires details about the type of business applying for approval including the status of the business, VAT registration details, details of people in charge of the business and contact details.

Section 2 — production and premises detail

You are required to confirm the type of alcoholic products to be produced under the approval including providing an estimated annual alcohol production figure in the current calendar year.

Details of each of the premises for approval are also required explaining the types of alcoholic products to be produced or held on the premises and the types of activities to be carried out on those products.

You will also need to provide details of alcoholic products producers connected to your business, and confirm if key people in the business comply with HMRC’s fit and proper test to your knowledge.

Regarding movements of alcoholic products, you must specify if you intend to import or export alcoholic products and whether you intend to move alcoholic products in duty suspension between other excise warehouses or from other approved premises.

Section 3 — send your application

You will be able to view the answers you have submitted in the final section of the application form. By submitting your application form, you will be confirming that the information you have provided is correct and complete.

Following submission of the application form, if you need to make any changes to the information provided in your application you should wait until HMRC contacts you. It is not possible to re-open the application online to make amendments.

We may refuse your approval if we discover the information you’ve given us is untrue or incomplete in any aspect, and you could be prosecuted or liable to penalties.

4.9 Non-digital customers

If you consider that you are digitally excluded, you can apply for an exemption from applying for an APPA online. An exemption applies if:
- it’s not practical for you to use software to keep digital records or submit them — this may be due to your age, disability, location or another reason
- you are a practising member of a religious society (or order) whose beliefs are incompatible with using electronic communications or keeping electronic records
You will need to set out how these circumstances apply to you by writing to:

HM Revenue and CustomsExcise Processing TeamBX9 1GLUnited Kingdom

We’ll consider the information you send us and we’ll either tell you:
- that you’re exempt (we’ll let you know what you need to do next)
- why you’re not exempt
If the reason for your exemption no longer applies you must tell HMRC within 3 months.

4.10 Premises approval

You must apply for authorisation of all premises where you produce and hold alcoholic product in duty suspension and premises where you want to receive alcoholic product in duty suspension for packaging.

An APPA will allow approved producers to hold alcoholic products on certain premises, and there is no geographical limit on where these premises may be located within the UK.

4.11 Premises plan

As part of your approval application, you are required to submit a plan of the premises you intend to use. The plan should show the position and description of each vessel or other piece of plant that you intend to use in the production of alcoholic products, and where the products are to be stored in duty suspense. The parts of the premises used for production and holding of alcoholic products in duty suspense (known as ‘the approved area’) should be clearly distinguished. The premises plan should also clearly mark fire exits in red. It should include any identifying marks on your vessels or plant and the full address of the premises.

4.12 Business plan

The approval application provides an option for producers to attach a business plan to their application. A business plan can help speed up the application process as it can help assure us of your suitability for approval, particularly if you are a new producer of alcoholic products without previous or existing approvals. In some instances, a business plan may be a requirement of the approval process.

There is no checklist of what we would expect to see within a business plan as each case will be different. However, we are expecting to see a business plan that is reasonable and proportionate to the size and complexity of the business and indicates that the approval application relates to commercial, viable and credible business activities.

Information on costings, suppliers, customer base, market research and profit forecasts will all build the picture we’re looking for of a well-considered and potentially successful business. We will ask for more information where plans lack enough detail for us to make a decision.

For help and advice read how to write a business plan (https://www.gov.uk/write-business-plan).

4.13 Temporary Storage Facilities

If you have a temporary need for additional storage space (due to seasonal demand) you can apply for any premises under your control to be approved temporarily.

The plan must be A4 size or less, and in black and white, with duty suspended areas shaded. The plan should be submitted as part of your application.

Retail premises within or attached to your approved premises are not considered part of the approved premises. Any alcoholic product moved to the retail premises will have to be duty paid on the removal from the approved premises.

4.14 After applying for approval

After applying for approval, we will check your application to see if it has been completed correctly and in full. If it’s incomplete, or is in any way unclear, we’ll ask you to supply the missing detail or clarify certain information. You should be prepared to provide these supporting documents within a reasonable timescale agreed with HMRC. Until we’re satisfied with the changes, we will not be able to process your application.

Your application will then be vetted and is subject to background checks, to satisfy ourselves that the information given is full and accurate and that you are suitable for approval. This will involve checks of our records to find out whether you have been compliant with your tax obligations and, in the case of a corporate body, are likely to include checks with Companies House. We may include checks with other government departments and agencies, and with credit reference agencies. We’ll also check the criminal records of applicants for any relevant convictions.

Should these checks provide insufficient assurance that the business is suitable for approval, more information can be requested. Until this information is received, your application will be put on hold. We may visit your place of business as part of the approval process. We will ask you for details about (but not limited to) your suppliers, customers, business plans, accounting and stock control systems, premises and financial viability. For information on what to expect, read compliance checks: excise visits — CC/FS16 (https://www.gov.uk/government/publications/compliance-checks-excise-visits-ccfs16).

After submitting your approval application, there will the option for you to withdraw your application before you are approved if you find you no longer require an APPA.

4.15 Withdrawing your approval application

After submitting your approval application, you have the option to withdraw your approval application before you are approved if you find you no longer require an APPA.

You can notify HMRC of your wish to withdraw an APPA application by email at xxx@xxx.xx (mailto:xxx@xxx.xx) or by writing to HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries).

You must provide your application reference number which you will have received when you submitted your application.

4.16 Fit and proper

We will only grant approval to applicants who can demonstrate that they are fit and proper to produce alcoholic products. This means HMRC must be satisfied the business is genuine and that all persons with an important role or interest in it are law abiding, responsible, and do not pose any significant threat in terms of potential revenue non-compliance or fraud.

HMRC will assess all applicants (not just the legal entity of the business but all partners, directors and other key persons) against a number of ‘fit and proper’ criteria to establish:
- assessments for duty unpaid stock or for other under declarations of tax that suggest there’s a significant risk associated with business trading in duty unpaid alcohol
- seizures of duty unpaid products
- penalties for wrongdoing or other civil penalties which suggest a business does not have a responsible outlook on its tax obligations
- trading with unapproved persons
- previous occasions where approvals have been revoked or refused for alcoholic products production or other regimes (including liquor licensing)
- previous confiscation orders and recovery proceedings under the Proceeds of Crime Act 2002 (https://www.legislation.gov.uk/ukpga/2002/29/contents)
- key persons have been disqualified as a director under company law
- there are no connections between the businesses, or key persons involved in the business, with other known non-compliant or fraudulent businesses
- key persons involved in the business have no criminal convictions which are relevant, for example, offences involving any dishonesty or links to organised criminal activity — we will normally disregard convictions that are spent provided there are no wider indications that the person in question continues to pose a serious threat to the revenue (an unspent conviction is one that has not expired under the terms of the Rehabilitation of Offenders Act 1974 (https://www.legislation.gov.uk/ukpga/1974/53))
- the application is accurate and complete and there has been no attempt to deceive HMRC
- there have not been persistent or negligent failures to comply with any HMRC recordkeeping requirements, for example poor record keeping in spite of warnings or absence of key business records
- the applicant, or key persons in the business, have not previously attempted to avoid being approved and traded unapproved
- the business has provided sufficient evidence of its commercial viability and credibility – HMRC will not approve applicants where they find that they cannot substantiate that there’s a genuine plan to legitimately trade from the proposed date of approval
- there are no outstanding, unmanaged debts to HMRC, or a history of duty or VAT not being paid on time
- the business has in place satisfactory due diligence procedures, covering its dealings with customers and suppliers to protect it from trading in illicit supply chains
This list is not exhaustive. HMRC may refuse to approve you for reasons other than those listed if they have justifiable concerns about your suitability to be approved for an APPA.

4.17 Application outcome

If we accept your application

We will issue you with an APPA ID and a confirmation of approval which will confirm the date of your approval plus details of any conditions that we’ve placed on your approval. The APPA ID is made up of 5 letters and 10 numbers (for example, XMADP0123459789).

Once approved, alongside your APPA ID, you will receive a letter of approval specifying:
- the types of alcoholic products you’re approved to produce
- the types of production related activities you’re authorised to carry out, such as holding alcoholic products in duty suspension
- the specific approved premises where the alcoholic products can be produced and held in duty suspension
If we refuse your application

We will inform you in writing and give our reasons. We will offer you a review of our decision or you can appeal directly to the independent tribunal.

4.17.1 Letter of indication

After you have applied for approval, HMRC may consider that you require further preparation work before you receive approval. For example, before issuing approval, we may expect to see comprehensive business plans and detailed information about processes.

Providing we are content with your plans, we can, on request, issue a letter of indication confirming we’re likely to approve your application based on the information that you have provided and subject to the outstanding preparation being completed. This allows HMRC to put your application on hold for 6 months while you provide the outstanding information. It is your responsibility to contact us. Once you have contacted HMRC, further checks will be made to confirm your status as a fit and proper person and that all requirements for an APPA have been met.

We also may issue a letter where a business is looking to secure necessary finance (for example, to purchase premises or invest money in alcohol production) and financial institutions have asked the applicant for an indication that an APPA will be granted by HMRC.

We’ll not issue a letter of indication if we’re not satisfied that you’ve demonstrate a genuine business purpose or if we have concerns about other aspects of your plan, for example, the security of alcoholic product once produced. We will not issue the final approval if there are significant changes or deviations from the original plans.

Failure to submit the required information within the time frame specified will mean we’ll close your application. You will then need to re-apply in full to HMRC for your APPA.

4.18 Obligations as a producer of alcoholic products

As an approved alcoholic products producer, you must:
- keep records of all alcoholic products produced, as outlined in section 9 — records and accounts (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-9-records-and-accounts)
- keep records of all alcoholic products leaving your approved premises, or otherwise passing the duty point
- calculate the duty due on all alcoholic products released for home use
- keep records of all alcoholic products destroyed
- complete and submit an Alcohol Duty return by the 15th day of the month for the previous accounting period
- pay the duty due by the 25th day of the month for the previous accounting period
Once you’re approved and you have your APPA ID, your obligation to submit monthly returns and payments will apply. Following receipt of your approval and APPA ID you should enrol onto the Manage your Alcohol Duty service (https://www.gov.uk/guidance/get-access-to-the-alcohol-duty-online-service) as soon as possible so you are ready to submit returns (https://www.gov.uk/guidance/submit-your-alcohol-duty-return) (including any ‘nil’ returns where you don’t have anything to declare in the period) and make payments (https://www.gov.uk/guidance/pay-alcohol-duty). If you do not enrol and submit returns and payments you may be liable to penalties.

If your alcoholic products are eligible for Small Producer Relief (https://www.gov.uk/guidance/check-if-youre-eligible-for-small-producer-relief-on-alcohol-duty), you must:
- calculate your Small Producer Relief rate before the start of each Small Producer Relief production year
- keep records of all pure alcohol in the product produced in an Alcohol Production Account
- keep records of all small producer product you handle in duty suspension
4.18.1 Security of approved premises and alcoholic products

The approved producer will be responsible for the security of all approved premises and the alcoholic products received, held, and released from those premises.

We’ll check to make sure your security systems protect the revenue. You must pay the duty on any losses you cannot explain.

Ensuring adequate security

This list is not prescriptive and aims to gives some examples of how producers can ensure there is adequate security in place.

Production site

Security must include perimeter and building security which deters casual entry and identifies signs of forced entry.

Regularly demonstrated by security reviews.

Still room

Security must include regular checks of vessels and plant and have restricted access.

Regularly demonstrated by management checks to ensure any lapses in security are put right.

Vessels and plant

Security must include measures to secure all vessel openings are locked or sealed and that signs of tampering or pilferage do not go unnoticed and technology of a high standard which controls access to all areas and vessels on the site.

Regularly demonstrated by security reviews and management checks.

4.19 Conditions of approval and revocations

There are standard conditions that must be complied with in order to remain approved. You must:
- continue to produce alcoholic products
- follow all the procedures set out in this guide, including the application of appropriate due diligence checks
Where we have reasonable cause, we can vary the terms of or revoke your approval, impose conditions affecting our approval or restrict the premises which are approved. For example, where appropriate due diligence checks are not being carried out, we identify risks to the revenue or failures to meet the fit and proper test. When this is necessary, we will inform you in writing giving our reasons for our action. We will offer you a review of our decision or you can appeal directly to the independent tribunal (https://www.gov.uk/guidance/appeals-and-tribunals-an-overview-for-agents-and-advisers).

Conditions can include either:
- limitation of the extent of approved premises
- requiring financial security for the duty on the alcoholic products in duty suspension
4.20 Duty guarantees

Producers applying for an approval for the first time are not required to arrange a duty guarantee unless specified by HMRC on an individual basis. If HMRC informs you to arrange a duty guarantee it must cover any duty due on alcoholic products removed from your approved premises to the UK home market, until it is paid to HMRC. For further information read section 8 — financial security (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-8-financial-security).

4.21 Temporary approval

You may be able to apply for temporary approval allowing your business to continue trading during the review of appeal process if HMRC rejects or revokes your approval. Read apply for temporary approval (https://www.gov.uk/guidance/apply-for-temporary-approval-for-the-alcohol-wholesaler-registration-scheme) for more information.

4.22 Visits by HMRC

We will make visits to make sure duty is being correctly calculated and accounted for on all alcoholic products leaving the approved premises and accurate records or removals and receipts are kept for duty suspended movements. Assurance is based on auditing your commercial accounting and management control systems and on physical checks. We will carry out physical checks on production, stock and movements of alcoholic products in duty suspension.

When we intend to carry out our checks, we will normally make an appointment, but may also make unannounced visits, particularly when undertaking physical checks. The attending officer will give the reason for the unannounced visit. At any reasonable time, you must permit our officers access to any area of the registered premises. You must make sure that all your security personnel are aware that we can visit without an appointment. All of our officers carry identification and will show this when they arrive.

4.23 Length of approval

Your approval will last until production has permanently ceased.

You must notify us:
- if you intend to permanently cease production
- when you’ve actually permanently ceased production
4.24 Permanently ceasing production

After production has stopped and your product is finished and packaged, you will have to pay the duty due on any:
- remaining stock in hand
- unexplained shortages
We may also allow you to destroy the alcoholic products in stock, as if it were unfit for sale. However, duty must be paid on unexplained shortages.

When we’re satisfied that you notified HMRC of your intention to permanently ceasing production, have accounted for all duty or destroyed your stock, we will cancel your approval. We will issue a cancellation letter confirming that you no longer hold an APPA and will need to re-apply for an APPA if you intend to commence production of alcoholic products in the future.

Where HMRC is not notified of production permanently ceasing, we will revoke your APPA and provide a revocation letter.

4.25 If your circumstances change and making amendments to your approval

After you have been approved, you are required to notify HMRC of changes affecting your APPA. This includes variations to details provided in your approval application, referred to in section 4.8 – how to apply for approval, and change of circumstances (#apply-approval).

Failure to comply with these requirements around notification of changes may mean you’re liable to penalties. It may also lead HMRC to reassess whether you’re fit and proper to be approved.

4.25.1 Notification of changes before they occur

For the following changes you must tell HMRC as soon as possible and prior to the change having occurred. This includes changes to:

status of the business, for example if you are operating as a sole trader, partnership, limited company or other status

financial difficulties or impeding insolvency
- addresses of approved premises and where it is different, address of the person holding the approval
- the plan of the approved premises
- cessation of any of your approved premises
- the details of any people being or becoming connected (as per section 1122 of the Corporation Tax Act 2010 – see section 12 of this guidance for further details (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-12-draught-relief-and-small-producer-relief)) with the business including their APPA ID
- the production of other excisable goods on your premises including producing other categories of alcoholic products
- types of alcoholic products held in duty suspension on your premises
- the types of activities carried out on alcoholic products on your premises
- if you are a small cider maker, changes to your annual production level meaning you produced more than 5 hectolitres of alcohol in the previous year and estimate to produce more than 5 hectolitres of alcohol in the current year
- if you require temporary storage facilities
- if you hold an APPA and wish to cancel your excise warehouse approval while retaining the ability to carry out activities authorised under your excise warehouse approval. HMRC would consider if amendments to your APPA are needed to authorise you to carry out these activities under your APPA
- the types of alcoholic products to be imported or exported
- where sending or receiving alcoholic products to or from other approved persons or excise warehouses, the approval numbers assigned to that approved person or excise warehouse
- where holding or moving alcoholic products in duty suspension
- conditions added to your approval: As outlined in Section 4.19 (#approval-conditions), HMRC can impose conditions on your approval or restrict the premises approved. If your circumstances change and you wish to request removal of conditions and restrictions you must apply for an amendment to your approval. You should notify HMRC of these change in circumstances prior to the occurrence.
4.25.2 Changes to notify within 14 calendar days of the change having occurred

Tell HMRC as soon as possible and no later than 14 calendar days of the change having occurred. This includes changes to:
- contact details of your business including phone number or email address of your business
- the unique taxpayer reference allocated to the business and UTR of individuals for sole proprietors and partnerships
- if applicable, the name, position in the business and contact details of the officer, employee or other person who submitted the application
- if applicable, details of your partners, including new partners and changes of address to existing partners
- if applicable, details of your directors, including new directors and changes of address to existing directors
- change in trading name
- details of your duty guarantor including changes to guarantees or a request to remove the guarantee
- ending production
How to notify HMRC of changes and amendments to approval

You can contact HMRC via email at xxx@xxx.xx (mailto:xxx@xxx.xx) or by writing to HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries).

In your letter or email you must provide:
- your APPA ID
- details of your business including name and address of the person holding the approval
- full details about the change of circumstances and if an amendment to your approval is required
If you email HMRC, you should also add ‘APPA amendment’ into the subject of your email.

Processing changes and amendments

It may take between 15 to 45 working days to process changes to your approval depending on the complexity.

Depending on the type of changes that are made it could be necessary for HMRC to carry out further checks to assure that you’re still fit and proper to be approved. Once these checks are complete HMRC will either issue an amended letter of approval or advise you of any concerns they have.

Once you receive your new and amended approval letter you must destroy your previous approval letter.

4.26 Change in ownership

You must submit a new approval application if there is a change:
- of legal entity, for example, formation of a limited company
- in the ownership or control of your business
If you sell your business, your approval will not transfer to the new owner. The new owner must apply for approval prior to trading.

If you are operating as a limited company and sell your business, the existing approvals will remain in force if the actual approved legal entity remains the same after a change in ownership subject to the fit and proper test.

For further information on your requirements when the business changes ownership, read section 6 — changes in ownership (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-6-changes-in-ownership).

4.27 Third-party wine production and Commercial Fruit Growers

There are several options to consider if you grow grapes and have them made into wine by a third-party wine producer holding an APPA:

When you will not need an APPA from HMRC:

you do not intend to sell the wine produced for you by the approved producer, you can receive it back without payment of duty if you give the producer a written declaration that it will not be sold

you as a vineyard (or lessee) as a ‘Commercial Grower’ intend to have your fruit vinified by an approved producer on your behalf and the producer pays the duty on the wine when it leaves their approved premises on the producer’s monthly return (payment of the amount equal to that wine duty to the producer is a commercial matter as re-charge to you)

When you will need an APPA from HMRC:
- If you will carry out any production, or part-production, on your premises. This includes where you produce even a minority amount of the final alcoholic product (wine), with the majority produced elsewhere. You must apply for approval before producing any alcoholic products.
4.27.1 Commercial Fruit Growers receiving wine produced elsewhere in duty suspense.

Commercial Growers are people that grow grapes from which wine is produced, but who do not produce that wine themselves. As a Commercial Grower you will require an appropriate excise warehouse approval if you wish to receive the wine from your grapes back under duty suspension.

You will need to apply for a trade facility warehouse approval through form EX69 (https://www.gov.uk/government/publications/excise-warehousing-trade-facility-warehouse-for-alcohol-and-tobacco-ex69) for the specific purpose of receiving the wine produced from your grapes back from an APPA-approved producer under duty suspension. You must include a business plan and a premises plan with your application. Further information on trade facility warehouse approval can be found at registration and approval of excise goods held in duty suspension (Excise Notice 196) (https://www.gov.uk/guidance/registration-and-approval-of-excise-goods-held-in-duty-suspension-excise-notice-196).

Your application to be approved as a trade facility warehouse will need to include details of the activities undertaken on your premises, details of the APPA premises your grapes will be sent to and received back from when made into wine. You will also need to satisfy HMRC that due record keeping will be adhered to and monthly returns, even when nil, will be submitted and payments made.

4.27.2 Returns and payments obligations for Commercial Fruit Growers with a trade facility warehouse approval

Following approval as a trade facility warehouse, Commercial Growers will be provided with an Alcohol Duty ID (AD ID) – a 15-character identifier – alongside their trade facility warehouse approval. The AD ID is distinct from the APPA ID and only applies to Commercial Growers with a trade facility warehouse approval.

Commercial Growers must use their AD ID to access the Manage your Alcohol Duty online service (https://www.gov.uk/guidance/get-access-to-the-alcohol-duty-online-service) to submit returns and payments by the 15th day of each month. This includes submitting a ‘nil’ return in months when no alcoholic products are released. Read section 5 for further information (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-5-returns-and-payments) about the online service.

4.27.3 Commercial Fruit Growers in operation before 1 February 2025

If you hold existing ‘approvals’ to operate as a Commercial Grower before 1 February 2025, you do not need to reapply. Your excising approvals will, where necessary, be transferred to a trade facility warehouse approval. You will receive a letter from HMRC confirming your trade facility warehouse approval and your Alcohol Duty ID (AD ID). If you have not received this letter contact xxx@xxx.xx (mailto:xxx@xxx.xx).

4.28 Production by unapproved persons on an unapproved premises

Except where an approval is not required, the production of alcoholic products by a person who is not approved, or on premises which are not included under an APPA is an offence for which there is a penalty.

You can avoid a penalty by applying for approval at the correct time. If you have applied for approval, you must notify us as soon as possible. Depending on the circumstances, we may be able to reduce the penalty. You have the right to appeal if we impose such a penalty.

4.29 Advice

For general enquiries, contact HMRC (https://www.gov.uk/find-hmrc-contacts/excise-warehousing-excise-goods-movements-and-alcohol-duties-enquiries). For enquiries about the alcoholic products producer approval (APPA) application process and your approval contact xxx@xxx.xx (mailto:xxx@xxx.xx).

Read HMRC compliance checks factsheets (https://www.gov.uk/government/collections/hm-revenue-and-customs-compliance-checks-factsheets) for more information.

Read disagree with a tax decision or penalty (https://www.gov.uk/tax-appeals) for more information.

Section 4 annex

These examples relate to section 4.6 (https://www.gov.uk/guidance/alcoholic-products-technical-guide/section-4-approvals#types-of-production).

Examples of different types of production and the required approvals

Scenario 1 — company A has 3 production premises

At premises 1 and 2, they produce spirits.

At premises 2 and 3, they hold the spirits they produce for maturation.

At premises 2 and 3, they bottle the spirits they produce.

At premises 2 and 3, they receive and hold spirits produced by a different company for maturation and bottling.

Company A will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce spirits at premises 1 and 2
- approved to hold spirits they produce themselves at premises 1, 2 and 3 without payment of duty
- approved to hold spirits produced elsewhere at premises 2 and 3 without payment of duty
- approved to hold spirits for maturation and package spirits at premises 2 and 3 without payment of duty
Scenario 2 — company B has 1 production premises

At the premises they produce, hold and bottle cider.

Company B also sends some of that cider in duty suspense to a distillery for mixing with spirits to produce a cider-based spirit. The company then receives the cider-based spirits in duty suspense and holds and bottles the product at their premises.

Company B will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce cider at their premises
- approved to hold the cider they produce themselves at their premises without payment of duty
- approved to hold spirits produced elsewhere at their premises without payment of duty
- approved to bottle cider and spirits at their premises without payment of duty
Scenario 3 — company C has 5 production premises

At premises 1, 2 and 3 they produce beer.

At premises 1, 2, 3, 4 and 5 they hold and package the beer they produce in duty suspension.

At premises 4 and 5 they hold and package beer that is produced at 3 different breweries.

At premises 2 they produce cider.

At premises 2 and 4 they hold and package the cider they produce.

Company C will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce beer at premises 1, 2 and 3
- approved to produce cider at premises 2
- approved to hold the beer they produce at premises 1, 2, 3, 4 and 5 without payment of duty
- approved to hold cider they produce at premises 2 and 4 without payment of duty
- approved to hold beer produced elsewhere at premises 4 and 5 without payment of duty
- approved to package beer at premises 2, 3, 4 and 5 without payment of duty
- approved to package cider at premises 2 and 4 without payment of duty
Scenario 4 — company D has 2 production premises

At premises 1 and 2 they receive spirits from 2 different distilleries and rectify those spirits.

At premises 1 and 2 they hold and bottle the spirits they produce (by rectifying).

Company D will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce spirits at premises 1 and 2
- approved to hold the spirts they produce at premises 1 and 2 without payment of duty
- approved to hold spirits produced elsewhere at premises 1 and 2 without payment of duty
- approved to package spirits at premises 1 and 2 without payment of duty
Scenario 5 — company E has 3 production premises

At all 3 premises, they import wine which is held in duty suspense.

At all 3 premises they hold casks of spirits for third parties.

Company E will not hold an alcoholic products producer approval (APPA) as no production of alcoholic products is undertaken by the company. Instead, they will be required to hold an excise warehouse approval.

Scenario 6 — company F has one production premises
- They receive bulk Scotch Whisky from an approved producer to package. Company F also colour the Scotch Whisky with caramel to prepare the product for bottling.
Company F will not need to hold an alcoholic products producer approval (APPA) as no production of alcoholic products is undertaken by the company. Company F will require an excise warehousing approval to receive and package the Scotch Whisky in duty suspension.

If Company F were also carrying out blending operations or mixing the Scotch Whisky with other alcoholic product, affecting the alcohol by volume or organoleptic properties of the Whisky, they will require an alcoholic products producer approval (APPA).

Scenario 7 — company G has one production premises

They conduct several Scotch Whisky production processes at this site involving fermentation, distillation, maturation and blending.

Company F requires an alcoholic products producer approval (APPA) which will state they are:
- approved to produce spirits at their premises
- approved to hold the spirits they produce at their premises without payment of duty