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?
Private individuals have never needed to register under WOWGR in order to own a cask. From 2025 “revenue traders” /businesses will also be 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.
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. 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” is different from an “owner of warehoused goods.” Therefore, the question you should be asking is, technically, do I need to be accepted onto the WOWGR register 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 warehouse 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 are being 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.
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. The important part for private individuals who are looking to buy casks is section 5.1 which states 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. (It is likely that this will need to be updated alongside the 2025 changes to WOWGR, we will update this when we have more details on how this will look.)
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 do not need a 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 that will no longer be the case.
How To Show You Are Not A Revenue Trader
There is no definition of a private individual stated in Excise Notice 196, only the definition of what a revenue trader is. As such, the legislation is open to quite a lot of interpretation. We adhere to the side of caution, and for this reason we recommended that private individuals should keep the number of casks owned at 5 or less, plan to hold those casks for the long term and not buy through a business account. From March 2025 these limitations should be removed.
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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
Until March 2025 you can apply to be the owner of duty suspended goods where you are not the registered warehousekeeper. Owners of warehoused goods cannot transfer ownership without the permission of the warehousekeeper.
Recognised by the letters GBOG preceding a number: e.g. GBOG1234567890 GBOG
GBOG = Great Britain Owner of Goods
Duty Representative Registration Certificate
A Duty Representative is licensed to represent overseas companies who own duty suspended goods. It is a separate certification under WOWGR and so not all warehousekeepers/owners etc. have the right to act as a duty representative. If you are a business based outside of the UK ensure the warehouse has a GBDR certificate in order to represent you.
Recognised by the letters GBDR preceding a number: e.g. GBDR1234567890 GBOG
GBDR = Great Britain Duty Representative
