A duty representative was someone authorised by HMRC to act as an agent for non-UK based businesses involved in the buying, selling and storage of duty suspended goods in UK excise warehouses.
WOWGR (Statutory Notice 1999 No. 1278: The Warehousekeepers and Owners of Warehoused Goods Regulations 1999) was updated in March 2025 and the provision of duty representatives has been removed.
Send Me The 2026 Cask Buying Guide
"*" indicates required fields
If you are an overseas business who had a duty representative to own casks purchased before March 2025 you should contact them to ensure the casks are properly recorded in your name at the warehouse level.
Do I need a duty representative to own a whisky cask?
As of March 2025 no one needs a duty representative; they do not exist in the updated WOWGR legislation.
Prior to this update only non-UK based businesses needed a duty representative to own casks stored in Scottish warehouses.
- If you were a private individual in the UK then you were not classed as a revenue trader and therefore you did not need a duty representative. Furthermore Statutory Notice No.1278 stated that a duty representative could not represent you as an agent.
- If you are a private individual based outside of the UK then you are still not classed as a revenue trader and therefore it is our understanding that you did not need a duty representative.
- If you own a cask or casks through a UK based business prior to March 2025 you were classed as a revenue trader as per Excise Notice 196 and had to apply to be a registered owner in order to store your casks in a registered excise warehouse (a registered owner was a revenue trader approved to deposit goods they own in an excise warehouse). In this instance a duty representative could not act for you as per Statutory instrument No.1278.
