Licenced stores will very soon need to answer this question, as retailers who sell alcohol in large quantities may be required to register as a wholesaler under new laws which come into force next year.


The Alcohol Wholesaler Registration Scheme is intended to ensure that only legitimate businesses trade in duty-paid alcohol, and to stamp out the fraudulent sale of products which costs the taxpayer £1.3bn a year in lost revenue. It requires all wholesalers to apply for registration from October, after which they will be assessed and inspected to ensure they are a ‘fit and proper’ alcohol trader.

The Federation of Wholesale Distributors is warning licenced retailers who sell to other businesses, or regularly sell large volumes to a single customer, that they may have to apply for registration.

A retailer who makes incidental high-volume sales, such as occasionally providing products for a community event, would not be required to register. However, if these sales were frequent, or part of the store’s business model (for example, if it advertises that it can cater for large events) then it would be deemed to be trading as a wholesaler and therefore need to apply for registration.

FWD chief executive James Bielby says: “We are concerned that many retailers many not realise that they are acting as a wholesaler. If they are, they need to apply for registration between October and December this year, or face possible penalties from January 1st 2016. They will also have to demonstrate that they are sourcing their alcohol legitimately, and keeping records of who they purchase from.”

HMRC has issued a flowchart to help retailers decide if the need to apply for registration. The online application process opens on October 1st and will be accessed through the Government Gateway,, for which retailers will also have to register.

AWRS Briefing pack

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