On the 3rd March 2025, new legislation came into force that impacts excise warehousekeepers, owners of warehoused goods and businesses operating within the excise supply chain. Changes to the Warehousekeepers and Owners of Warehoused Goods Regulation (WOWGR) are substantial and the impact on whisky maturation and warehousing significant. From today, the registration requirement for owners of goods and duty representatives is to be removed, they will no longer be required to register with HMRC. Under WOWGR reform, only warehousekeepers have to register, so they can operate an excise warehouse.

 on the whisky industry, here, we look at the latest updates on the day reform arrives, and what it all means for the industry as we move forward.

Our CEO Rob Hollands, recently joined a webinar with The Bonded Warehousekeepers Association (BWA) on how technology unlocks new levels of efficiency and compliance, enabling warehouses to optimise space, track and manage assets efficiently, enhance traceability and reduce the compliance burden. As the BWA says, ‘This is especially relevant with WOWGR reform’. Watch in full 

HMRC has made several amendments to the guidance on GOV.UK, including:

Removal of duty representatives - References to Duty Representatives have been removed across multiple sections, indicating a shift in how HMRC expects businesses to manage their excise responsibilities.

Clarifications on warehouse storage - The guidance on storing goods in excise warehouses has been revised, removing references to the previous Duty Representative model and updating details on warehouse storage permissions.

Record-keeping requirements - Updates have been made to the manual records section, including the removal of previous requirements that referenced manual logging processes for warehouse stock.

Due diligence changes - The removal of references to registered owners and Duty Representatives suggests an evolution in HMRC’s approach to compliance and risk management within excise warehousing.

Movement and control of goods - Adjustments have been made to guidance on the receipt, storage, and movement of excise goods, ensuring alignment with new procedural requirements.

In addition to the guidance changes, several forms used for excise warehousing applications are being phased out, including:

EX60 and EX60A - These forms, previously used to register for excise warehousing, are being withdrawn.

FPEX60 and FPEX60A - Freeport-specific excise warehousing applications are also being removed.

Government Gateway Access - Some application processes linked to the tax service platform will no longer be applicable.

Warehousekeeper applications - Additional changes include the removal of the online and paper-based application pathways for certain warehousekeeper registrations.

These changes aim to simplify HMRC’s regulatory approach to excise warehousing, making it easier for businesses to navigate. A first step for many is to review their current processes to ensure compliance with the updated requirements, and if businesses previously relied on a Duty Representative or specific forms for registration, they may need to adjust their approach.

Due diligence remains a priority for warehousekeepers with accurate record-keeping the cornerstone to compliance. The move from manual paper-based records to a secure and compliant digitalised solution is on the cards for many as they look for greater transparency and data integrity to account for every aspect of barrel management from location to ownership, status and movement.

A key driver for digitalisation in the industry

, talks about how they have prepared for WOWGR reform by embracing technology. 

“WOWGR reform presents both challenges and opportunities for third-party maturation facilities. By prioritising data accuracy, operational integrity, and customer trust, and underpinning our entire operation with the 

, we mitigate risk and enhance our service offerings in the evolving landscape of the Irish Whiskey Industry."

The move away from paper-based records and other less suitable tools, like 

, provides a real opportunity for better data, capacity planning, reduced administration and risk of errors. Whilst there’s challenges in the short-term to adapt to new measures, the opportunities for digitalisation address the unique needs of the industry. Benefits such as greater supply chain transparency and assurance of cask ownership will be welcomed widely.

We’re helping many whisky warehouses address the incoming WOWGR changes and become more operationally efficient.

If you’re looking to digitalise your warehouse and get ahead of WOWGR 

 with our team for a demo of our solution. We’ll tell you how we’re transforming the spirits sector with our Proof 8 platform that’s been specifically designed in partnership with distilleries and warehouses, such as The Foundry Vault.

“Accurate record-keeping is the cornerstone to compliance”

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WOWGR reform – Accelerating digital compliance

WOWGR reform – Accelerating digital compliance

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WOWGR reform – Accelerating digital compliance

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