One of the questions that we get asked the most in terms of cask investment is: what is a WOWGR and do I need one in order to buy a cask?
The simple answer is no; as of March 2025 only Warehouses and Warehousekeepers can be certified under WOWGR. Anyone else can still own casks, either as a private individual or business, without needing any kind of WOWGR certificate.
Private individuals have never needed to register under WOWGR in order to own a cask. From 2025 “revenue traders” /businesses also became excluded from WOWGR certification. Read more about the 2025 updates to WOWGR here, and see below for a summary of the historic WOWGR certification with updates for 2025.
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WOWGR is short for Warehousekeepers and Owners of Warehoused Goods Regulations 1999; until March 3 2025 WOWGR was a register that all revenue traders had to be accepted onto in order to own whisky held in duty suspense. Following the update it is only Warehousekeepers that are covered by the regulations.
When you are accepted onto the register you receive a certificate that states which part of the regulations you are covered by. For example a “warehousekeeper” was different from an “owner of warehoused goods.” Therefore, the question you should be asking is, technically, do I need to be regulated by WOWGR in order to buy a cask?
The below video covers WOWGR prior to the 2025 changes, or read on for more details.
Do I Need A WOWGR To Get A Delivery Order?
When you buy a cask you will usually receive a delivery order (or some other equivalent, the important thing is it is from the Warehousekeeper not your broker/dealer). The delivery order ensures that ownership of the cask is transferred into your name at the warehouse where the cask is stored and not just at the company that sold you the cask. Private individuals do not, and have never, needed to be WOWGR registered in order to own a cask with a delivery order.
WOWGR 1999 was specific to Revenue Traders in the UK. So the important part as a private individual that pays tax in the UK was to ensure you don’t do anything with casks that could be classed as trading. From March 3rd 2025 the “OWG” sections of WOWGR has been removed and only “Warehousekeepers” will be able to be certified. If you don’t pay tax in the UK then WOWGR never applied to you.
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The Surrounding Legislation: Excise Notice 196
Excise Notice 196 outlines the legislation surrounding excise goods held in duty suspension in the UK. This applies to casks as they are held in duty suspension whilst they are in bond. This notice has also been updated following the changes to WOWGR, prior the the changes section 5.1 stated that:
“All owners of duty-suspended excise goods must obtain approval and registration, unless […] the owner of the excise goods is not a revenue trader”.
The “approval and registration” here refers to WOWGR. This section has been removed following the update, clarifying that no registration is needed for anyone other that Warehousekeepers.
What Is A Revenue Trader?
The definition of ‘revenue trader’ according to the gov.uk website is:
“[(a)] any person carrying on a trade or business subject to any of the revenue trade provisions of the customs and excise Acts”
That means that even before the 2025 changes, as long as you purchase the duty suspended goods (i.e. casks) as a private individual you did not need to be certified under WOWGR. Although prior to the changes if the owner was perceived to be trading in duty suspended goods (i.e. buying and selling casks frequently for profit ) then that person would need to register. From March 2025 “Owners” who are not Warehousekeepers are not governed by WOWGR.
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The Different Ways To Be WOWGR Certified
Prior to March 2025 WOWGR covered both “Warehousekeepers” and “Owners of Warehoused Goods.” Each of the below are the different certifications that were governed by WOWGR. We will update it once the Statutory Instrument has been updated online.
Authorised Warehousekeeper Registration Certificate
This is what most people thing about when discussing WOWGR. It is the registration someone at the warehouse needs to have in order to maintain and change the records of ownership at that warehouse.
Recognised by the letters GBWK preceding a number: e.g. GBWK1234567890
GBWK = Great Britain Warehouse Keeper
General Storage and Distribution Warehouse Approval Number
This is the number given to a particular warehouse. For instance, Diageo might have 1 Warehousekeeper but 100 different warehouses. A new certificate is required for each site.
Recognised by the letters GB preceding a number: e.g. GB1234567890
Registered Owners of Duty Suspended Goods held in Excise Warehouses
This section of WOWGR has been removed as of March 2025. It was previously recognised by the letters GBOG preceding a number: e.g. GBOG1234567890
GBOG = Great Britain Owner of Goods
Duty Representative Registration Certificate
Prior to March 2025 a Duty Representative was a business licensed to represent overseas companies who own duty suspended goods. It was a separate certification under WOWGR and so not all warehousekeepers/owners etc. had the right to act as a duty representative.
Recognised by the letters GBDR preceding a number: e.g. GBDR1234567890 GBOG
GBDR = Great Britain Duty Representative
