WHAT IS A DUTY REPRESENTATIVE?
What Is A Duty Representative? And Do You Need One?
Statutory Notice 1999 No. 1278: The Warehousekeepers and Owners of Warehoused Goods Regulations 1999 – also known as WOWGR – was updated in March 2025 and the whole of section III covering Duty Representatives was removed.
This means that you cannot have a duty representative because no one can be one.
What Was A Duty Representative?
Under the old definition, a duty representative was someone authorised by HMRC to act as an agent for non-UK businesses involved in the buying, selling and storage of duty suspended goods in UK excise warehouses. Even before the update you only needed a duty representative if you were a non-UK based business.
You can see the old version of WOWGR here: Statutory Notice 1999 No. 1278: The Warehousekeepers and Owners of Warehoused Goods Regulations 1999.
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Duty Representatives: What They Could and Could Not Do
As described in the original statutory instrument 1999 No. 1278 part III: a duty representative was a ‘revenue trader’ i.e. a registered UK based business or individual, who has obtained the relevant approvals to act as the agent for other revenue traders. (The Warehousekeepers and Owners of Warehoused Goods Regulations 1999 > UK Statutory Instruments 1999 No. 1278 Part III. 6.—(1) to (3)).
In the original Statutory instrument 1999 No. 1278, part VII stated that you could not have a duty representative act as an agent for you if you have any business or fixed establishment in the UK, or your usual place of residence is in the UK. (The Warehousekeepers and Owners of Warehoused Goods Regulations 1999 > UK Statutory Instruments 1999 No. 1278 Part VII. 19.—(6)).
Part VII also stated that a warehousekeeper could keep goods in their warehouse that belong to either: a registered owner, someone with a duty representative, or anyone who is not a registered trader. (The Warehousekeepers and Owners of Warehoused Goods Regulations 1999 > UK Statutory Instruments 1999 No. 1278 Part VII. 17.—(2) to (3)).
For a complete understanding of what a duty representative is following the updates, as well as details about warehousekeepers and registered owners (now removed) you should consider reading the full details in Instrument No. 1278. You can also get in touch and we will be happy to chat to you about what your particular requirements may be regarding storage of a cask.
