Section 4 — approvals
Information on how and when to apply for approval as an alcoholic products producer and the information you must provide as part of your approval to prove that you are fit and proper.
From 1 February 2025, all producers of alcoholic products are required to hold an alcoholic products producer approval (APPA).
If you are producing alcoholic products, or carrying out activities on alcoholic products which changes their alcohol by volume, product classification or produces an alternative product, you are now considered to be an alcohol producer and must hold an alcoholic products producer approval (APPA). Importing finished alcoholic products, solely holding and storing third party goods or bottling bulk product without altering it is not classified as production. For more information on what is classified as production, read section 3 — production of alcoholic products.
You must first be approved as an alcoholic products producer before you start producing alcoholic products on your approved premises. The proprietor, partnership or company intending to produce alcoholic products must apply for approval.
If you are an approved producer, any alcoholic product you produce for your own domestic consumption will be liable to Alcohol Duty.
For more information about whether you require an approval and how to apply read:
You are exempt from the requirement to apply for approval as a producer if you:
- only produce alcoholic products (excluding spirits) that are for your own domestic use
- produce alcoholic products for research purposes or experiments into the production of alcoholic products only
If you only package but do not produce alcoholic product (that is, you put bulk alcoholic product produced elsewhere into containers) you do not require, and will not be approved for, an alcoholic products producer approval (APPA). You will be required to hold an excise warehouse approval if you want to package the product in duty suspension. For more information read receive goods into and remove goods from an excise warehouse (Excise Notice 197).
Your approval may authorise you to:
- produce the type of alcoholic products you are approved to produce on your approved premises (these are any premises in respect of which an approved person holds an alcoholic products producer approval (APPA) and are considered a tax warehouse for the purposes of excise legislation) and hold them in duty suspense — for example, beer, cider, wine, spirits or other fermented products
- carry out activities on the alcoholic products you’re approved to hold in duty suspension on your approved premises — this may include blending, maturation, packaging (including canning and bottling) aeration and pasteurisation, amongst others
- move duty suspended alcoholic products to other appropriately approved UK excise warehouses or approved premises — for Northern Ireland based producers, you can also remove duty suspended products to appropriately approved EU warehouses
- receive and hold alcoholic products produced elsewhere in duty suspense and import alcoholic products directly to your approved premises
Your approval may cover multiple premises and categories of alcoholic products. In addition to production premises, HMRC may authorise premises, approved under your alcoholic products producer approval (APPA), to hold alcoholic products in duty suspension, including alcoholic products produced elsewhere. There are no restrictions on where these premises can be located in relation to the distance from the production premises. Your approved premises are considered a tax warehouse for the purposes of excise legislation.
An alcoholic products producer approval (APPA) does not automatically permit you to produce all alcoholic products or carry out all of these activities. Your approval does not allow you to receive other types of alcoholic product, which you are not approved to receive.
Under the alcoholic products producer approval (APPA) you can be authorised to produce, hold and move alcoholic products in duty suspension. This means there is no longer a requirement for alcoholic product producers to operate an excise warehouse as they will be able to keep goods in duty suspense on their approved premises instead. This does not apply to importers or producers based overseas.
For example, an alcoholic products producer may be authorised to produce beer, and the approval may also cover the ability to hold cider produced elsewhere on their approved premises in duty suspension.
If an alcoholic products producer with an alcoholic products producer approval (APPA) wishes to hold an excise warehouse away from their approved premises or use a third-party excise warehouse, they can do. In this case existing warehousing obligations apply for the purposes of their excise warehouse. If they prefer, producers will be able to keep alcoholic products in duty suspension on approved premises.
Legacy registrations and licenses
Prior to 1 February 2025 all of your production premises required a separate registration or license under the Alcoholic Liquor Duties Act 1979. If you were registered or licensed to produce alcoholic products prior to 1 February 2025 you do not need to apply for an APPA. Your separate registrations and licenses will be migrated to a single new APPA. In February 2025 you will receive an online service letter from HMRC confirming the details of your new alcohol approval and your APPA ID. If you have not received a letter by 25 February 2025, please contact [email protected].
Compounding and rectifying
Prior to 1 February 2025, if you carried out activities on duty-suspended alcoholic products such as rendering wine or cider sparkling, or compounding (re-distilling) and rectifying (mixing) spirits, you were required to hold an excise warehouse approval, with the business authorised as an excise warehouse keeper. This is no longer a requirement for spirits producers because an alcoholic products producer approval (APPA) will provide you with approval to produce a type of alcoholic product and hold alcoholic products in duty suspense. Your alcoholic products producer approval (APPA) can also authorise you to rectify and compound spirits in duty suspension that you do not produce. If you hold an alcoholic products producer approval (APPA), there is no longer a requirement to perform these activities in an excise warehouse. You may wish to operate (or continue to operate) an excise warehouse, and further guidance on this can be found at registration and approval of excise goods held in duty suspension (Excise Notice 196).
If you operate (or continue to operate) an excise warehouse, and pay the duty due through Alcohol and Tobacco Warehousing Declarations, you will still be required to submit the monthly nil Alcohol Duty return required as an approved alcoholic product producer online by the 15th day of the month.
Small cider makers
Prior to 1 February 2025, cidermakers who produced less than 5 hectolitres of pure alcohol in cider and no other alcoholic products were exempt from the requirement to register for production. From 1 February 2025, they must now apply for an alcoholic products producer approval (APPA) with HMRC.
Examples of the required approvals
The annex in this section of the technical guide includes examples of the required approvals for different types of production activity.
When applying for approval, you should specify the alcoholic products, activities and premises you require approval for. If you intend to produce more than one type of alcoholic product, or you intend to produce at more than one premises, you should include the details of all alcoholic types you wish to produce and all the premises you wish to carry out production at in your approval application. If you need to update your approval, such as by seeking approval to produce other alcoholic products, read section 4.25 if your details change and making changes to your approval.
From 1 February 2025, alcohol producers can apply for an alcoholic products producer approval (APPA) online. We’ll tell you about how to apply for an alcoholic products producer approval (APPA) at a later date before the application process opens.
The apply for alcoholic products producer approval guidance provides more information about the application process.
When applying for approval you will be required to provide:
- the name and address of the applicant
- information on the status of your business, for example, if you are operating as a sole trader, partnership, limited company or other status
- the addresses of the premises to be approved and where it is different, the address of the applicant
- the plan of the premises to be approved
- if applicable, the name, position in the business and contact details of the officer, employee or other person responsible for making the application on behalf of the applicant
- the unique taxpayer reference (UTR) allocated to the business and the unique taxpayer reference (UTR) of individuals for sole proprietors and partnerships
- the details of any people being or becoming connected with the applicant including their alcoholic products producer approval (APPA) ID
- the category or categories of alcoholic products produced on the premises to be approved
- the date the applicant plans to begin the production of the alcoholic products
- an estimate of the quantity of alcoholic products to be produced by the applicant in the calendar year the application is made in your premises. You must make a note in your business records of how you’ve made the estimate
- where importing or exporting alcoholic products, the category or categories of alcoholic product to be imported or exported
- where sending or receiving alcoholic products to or from other approved persons or excise warehouses, the approval numbers assigned to that approved person or excise warehouse.
You should allow plenty of time between your application for approval and when you intend to start production. We will aim to process your application within 45 working days but this may take longer if you have not provided all the information we need to make a decision. You may track the progress of your application via the digital service.
We may refuse your approval if we discover the information you’ve given us is untrue or incomplete in any aspect, and you could be prosecuted or liable to penalties.
We will publish further guidance on who to contact if you are unable to use the online service or require help to complete the alcoholic products producer approval (APPA) application.
If you consider that you are digitally excluded, you can apply for an exemption from using the online approvals service. You can apply if:
- it’s not practical for you to use software to keep digital records or submit them — this may be due to your age, disability, location or another reason
- you are a practising member of a religious society (or order) whose beliefs are incompatible with using electronic communications or keeping electronic records.
You will need to set out how these circumstances apply to you by contacting excise and gambling duties enquiries.
We’ll consider the information you send us and we’ll either tell you:
- that you’re exempt (we’ll let you know what you need to do next)
- why you’re not exempt
If you’re not exempt you’ll need to enrol onto the approvals digital service.
If the reason for your exemption no longer applies you must tell HMRC within 3 months.
You must apply for authorisation of all premises where you produce and hold alcoholic product in duty suspension and premises where you want to receive alcoholic product in duty suspension for packaging.
An alcoholic products producer approval (APPA) will allow approved producers to hold alcoholic products on certain premises, and there is no geographical limit on where these premises may be located within the UK.
As part of your approval application, you are required to submit a plan of the premises you intend to use. The plan should show the position and description of each vessel or other piece of plant that you intend to use in the production of alcoholic products, and where the products are to be stored. The premises plan should also clearly mark fire exits in red. It should include any identifying marks on your vessels or plant and the full address of the premises.
The approval application provides an option for producers to attach a business plan to their application. In some instances, a business plan may be a requirement of the approval process. This can help assure us of your suitability for approval, particularly if you are a new producer of alcoholic products without previous or existing approvals.
There is no checklist of what we would expect to see within a business plan as each case will be different. However, we are expecting to see a business plan that is reasonable and proportionate to the size and complexity of the business and indicates that the approval application relates to commercial, viable and credible business activities.
Information on costings, suppliers, customer base, market research and profit forecasts will all build the picture we’re looking for of a well-considered and potentially successful business. We will ask for more information where plans lack enough detail for us to make a decision.
For help and advice read how to write a business plan.
If you have a temporary need for additional storage space (due to seasonal demand) you can apply for any premises under your control to be approved temporarily.
The plan must be A4 size or less, and in black and white, with duty suspended areas shaded. The plan should be submitted as part of your application.
Retail premises within or attached to your approved premises, are not considered part of the approved premises. Any alcoholic product moved to the retail premises will have to be duty paid on the removal from the approved premises.
After applying for approval, we will check your application to see if it has been completed correctly and in full. If it’s incomplete, or is in any way unclear, we’ll ask you to supply the missing detail or clarify certain information. You should be prepared to provide these supporting documents within a reasonable timescale agreed with HMRC. Until we’re satisfied with the changes, we will not be able to process your application.
Your application will then be vetted and is subject to background checks, to satisfy ourselves that the information given is full and accurate and that you are suitable for approval. This will involve checks of our records to find out whether you have been compliant with your tax obligations and, in the case of a corporate body, are likely to include checks with Companies House. We may include checks with other government departments and agencies, and with credit reference agencies. We’ll also check the criminal records of applicants for any relevant convictions.
Should these checks provide insufficient assurance that the business is suitable for approval, more information can be requested. Until this information is received, your application will be put on hold. We may visit your place of business as part of the approval process. We will ask you for details about (but not limited to) your suppliers, customers, business plans, accounting and stock control systems, premises, and financial viability. For information on what to expect, read compliance checks: excise visits – CC/FS16.
After submitting your approval application, there will the option for you to withdraw your application before you are approved if you find you no longer require an alcoholic products producer approval (APPA).
We will only grant approval to applicants who can demonstrate that they are fit and proper to produce alcoholic products. This means HMRC must be satisfied the business is genuine and that all persons with an important role or interest in it are law abiding, responsible, and do not pose any significant threat in terms of potential revenue non-compliance or fraud.
HMRC will assess all applicants (not just the legal entity of the business but all partners, directors and other key persons) against a number of ‘fit and proper’ criteria to establish:
- there’s no evidence of illicit trading indicating the business is a serious threat or that key persons involved in the business have been previously involved in significant revenue non-compliance or fraud, either within excise or other regimes — some examples of evidence we would consider are:
- assessments for duty unpaid stock or for other under declarations of tax that suggest there’s a significant risk associated with business trading in duty unpaid alcohol
- seizures of duty unpaid products
- penalties for wrongdoing or other civil penalties which suggest a business does not have a responsible outlook on its tax obligations
- trading with unapproved persons
- previous occasions where approvals have been revoked or refused for alcoholic products production or other regimes (including liquor licensing)
- previous confiscation orders and recovery proceedings under the Proceeds of Crime Act 2002
- key persons have been disqualified as a director under company law
- there are no connections between the businesses, or key persons involved in the business, with other known non-compliant or fraudulent businesses
- key persons involved in the business have no criminal convictions which are relevant for example, offences involving any dishonesty or links to organised criminal activity — we will normally disregard convictions that are spent provided there are no wider indications that the person in question continues to pose a serious threat to the revenue (an unspent conviction is one that has not expired under the terms of the Rehabilitation of Offenders Act 1974)
- the application is accurate and complete and there has been no attempt to deceive HMRC
- there have not been persistent or negligent failures to comply with any HMRC recordkeeping requirements, for example poor record keeping in spite of warnings or absence of key business records
- the applicant, or key persons in the business have not previously attempted to avoid being approved and traded unapproved
- the business has provided sufficient evidence of its commercial viability and credibility – HMRC will not approve applicants where they find that they cannot substantiate that there’s a genuine plan to legitimately trade from the proposed date of approval
- there are no outstanding, unmanaged debts to HMRC, or a history of duty or VAT not being paid on time
- the business has in place satisfactory due diligence procedures, covering its dealings with customers and suppliers to protect it from trading in illicit supply chains.
This list is not exhaustive. HMRC may refuse to approve you for reasons other than those listed if they have justifiable concerns about your suitability to be approved for an alcoholic products producer approval (APPA).
If we accept your application
We will issue you with an alcoholic products producer approval (APPA) ID and a confirmation of approval which will confirm the date of your approval plus details of any conditions that we’ve placed on your approval. The alcoholic products producer approval (APPA) ID is made up of 5 letters and 10 numbers (for example, XMADP0123459789).
Once approved, alongside your alcoholic products producer approval (APPA) ID, you will receive a letter of approval specifying:
- the types of alcoholic products you’re approved to produce
- the types of production related activities you’re authorised to carry out, such as holding alcoholic products in duty suspension
- the specific approved premises where the alcoholic products can be produced and held in duty suspension
If we refuse your application
We will inform you in writing and give our reasons. We will offer you a review of our decision or you can appeal direct to the independent tribunal.
As an approved alcoholic products producer, you must:
- keep records of all alcoholic products produced, as outlined in section 9 — records and accounts
- keep records of all alcoholic products leaving your approved premises, or otherwise passing the duty point
- calculate the duty due on all alcoholic products released for home use
- keep records of all alcoholic products destroyed
- complete and submit an Alcohol Duty return by the 15th day of the month for the previous accounting period
- pay the duty due by the 25th day of the month for the previous accounting period
If your alcoholic products are eligible for Small Producer Relief, you must:
- calculate your Small Producer Relief rate before the start of each Small Producer Relief production year
- keep records of all pure alcohol in the product produced in an Alcohol Production Account
- keep records of all small producer product you handle in duty suspension
4.17.1 Security of approved premises and alcoholic products
The approved producer will be responsible for the security of all approved premises and the alcoholic products received, held, and released from those premises.
We’ll check to make sure your security systems protect the revenue. You must pay the duty on any losses you cannot explain.
Ensuring adequate security
This list is not prescriptive and aims to gives some examples of how producers can ensure there is adequate security in place.
Production site
Security must include perimeter and building security which deters casual entry and identifies signs of forced entry.
Regularly demonstrated by security reviews.
Still room
Security must include regular checks of vessels and plant and have restricted access.
Regularly demonstrated by management checks to ensure any lapses in security are put right.
Vessels and plant
Security must include measures to secure all vessel openings are locked or sealed and that signs of tampering or pilferage do not go unnoticed and technology of a high standard which controls access to all areas and vessels on the site.
Regularly demonstrated by security reviews and management checks.
There are standard conditions that must be complied with in order to remain approved. You must:
- continue to produce alcoholic products
- follow all the procedures set out in this guide, including the application of appropriate due diligence checks
Where we have reasonable cause, we can vary the terms of or revoke your approval, impose conditions affecting our approval or restrict the premises which are approved. For example, where appropriate due diligence checks are not being carried out. When this is necessary, we will inform you in writing giving our reasons for our action. We will offer you a review of our decision or you can appeal direct to the independent tribunal.
Conditions can include either:
- limitation of the extent of approved premises
- requiring financial security for the duty on the alcoholic products in duty suspension
Producers applying for an approval for the first time are not required to arrange a duty guarantee unless specified by HMRC on an individual basis. If HMRC informs you to arrange a duty guarantee it must cover any duty due on alcoholic products removed from your approved premises to the UK home market, until it is paid to HMRC. For further information read section 8 — financial security.
You may be able to apply for temporary approval allowing your business to continue trading during the review of appeal process if HMRC rejects or revokes your approval. Read apply for temporary approval for more information.
We will make visits to make sure duty is being correctly calculated and accounted for on all alcoholic products leaving the approved premises and accurate records or removals and receipts are kept for duty suspended movements. Assurance is based on auditing your commercial accounting and management control systems and on physical checks. We will carry out physical checks on production, stock and movements of alcoholic products in duty suspension.
When we intend to carry out our checks, we will normally make an appointment, but may also make unannounced visits, particularly when undertaking physical checks. The attending officer will give the reason for the unannounced visit. At any reasonable time, you must permit our officers access to any area of the registered premises. You must make sure that all your security personnel are aware that we can visit without an appointment. All of our officers carry identification and will show this when they arrive.
Your approval will last until production has permanently ceased. We will revoke an approval if a producer permanently ceases production. We may also revoke an approval where we identify risks to the revenue or failures to meet the fit and proper test.
You must notify us:
- if you intend to permanently cease production
- when you’ve actually permanently ceased production
After you have applied for approval, HMRC may consider that you require further preparation work before you receive approval. For example, before issuing a letter, we may expect to see comprehensive business plans and detailed information about processes.
Providing we are content with your plans, we can, on request, issue a letter of indication confirming we’re likely to approve your application based on the information that you have provided and subject to the outstanding preparation being completed. This allows HMRC to put your application on hold for 6 months and for you to re-submit your application when ready to apply for final approval.
We’ll not issue a letter of indication if we’re not satisfied that you’ve demonstrate a genuine business purpose or if we have concerns about other aspects of your plan, for example, the security of alcohol once produced. We will not issue the final approval if there are significant changes or deviations from the original plans.
We also may issue a letter where a business is looking to secure necessary finance (for example, to purchase premises or invest money in alcohol production) and financial institutions have asked the applicant for an indication that an alcoholic products producer approval (APPA) will be granted by HMRC.
We will close the application if we have not heard from you in a reasonable time from issuing the letter of indication, and you will need to start the process again if you wish to proceed. It is your responsibility to contact us.
After production has stopped and your product is finished and packaged, you will have to pay the duty due on any:
- remaining stock in hand
- unexplained shortages
We may also allow you to destroy the alcoholic products in stock, as if it were unfit for sale. However, duty must be paid on unexplained shortages.
When we’re satisfied that you have accounted for all duty or destroyed your stock, we will cancel your approval.
After you have been approved, you are required to notify HMRC of changes affecting your alcoholic products producer approval (APPA). This includes variations to details provided in your approval application and change of circumstances.
You must notify HMRC of any changes to the details provided in your approval application, referred to in section 4.6 types of production and the required approvals. There will be an avenue to report a change in circumstances to ensure your records are kept up to date. We will publish guidance in due course on this.
Tell HMRC as soon as possible. This includes:
- changes of partner details
- changes of directors details
- change of your duty guarantor
- change of address of your approved premises
- change of phone number and email address for your business
- change in trading name
- changes in VAT status, such as your business becomes VAT registered or de-registered
- cessation of production
- cessation of any of your approved premises
- the production of other excisable goods on your premises, including producing other categories of alcoholic products
- financial difficulties or impeding insolvency
Depending on the type of changes that are made it could be necessary for HMRC to carry out further checks to assure that you’re still fit and proper to be approved. Once these checks are complete HMRC will either issue an amended letter of approval or advise you of any concerns they have.
Failure to comply with any of these conditions regarding notification of changes may mean you’re liable to penalties. It may also lead HMRC to reassess whether you’re fit and proper to be approved.
You must submit a new approval if there is a change:
- of legal entity, for example, formation of a limited company
- in the ownership or control of your business
If you sell your business, your approval will not transfer to the new owner. The new owner must apply for approval prior to trading.
If you are operating as a limited company and sell your business, the existing approvals will remain in force if the actual approved legal entity remains the same after a change in ownership subject to the fit and proper test.
For further information on your requirements when the business changes ownership, read section 6 — changes in ownership.
There are several options to consider if you grow grapes and have them made into wine by a third-party wine producer holding an alcoholic products producer approval (APPA):
When you do not need approval from HMRC:
- when you do not intend to sell the wine produced for you by the approved producer, you can receive it back without payment of duty if you give the producer a written declaration that it will not be sold
- when you as a vineyard (or lessee) as a ‘commercial grower’ intend to have your fruit vinified by an approved producer on your behalf and the producer pays the duty on the wine when it leaves their approved premises on the producer’s monthly return (payment of the amount equal to that wine duty to the producer is a commercial matter as re-charge to you)
When you will need approval from HMRC:
If you send your grapes to be vinified by a third party approved wine producer and want to receive the wine from your grapes back under duty suspension, you need to hold the appropriate excise warehouse approval. For further information read registration and approval of excise goods held in duty suspension (Excise Notice 196).
If you intend to carry out any production on your premises, you must apply for an alcoholic products producer approval (APPA).
Except where an approval is not required, the production of alcoholic products by a person who is not approved, or on premises which are not included under an alcoholic products producer approval (APPA) is an offence for which there is a penalty. You can avoid a penalty by applying for approval at the correct time. If you have applied for approval, you must notify us as soon as possible. Depending on the circumstances, we may be able to reduce the penalty. You have the right to appeal if we impose such a penalty.
Read HMRC compliance checks factsheets for more information.
Read disagree with a tax decision or penalty for more information.
These examples relate to section 4.6.
Examples of different types of production and the required approvals
Scenario 1 — company A has 3 production premises
At premises 1 and 2, they produce spirits.
At premises 2 and 3, they hold the spirits they produce for maturation.
At premises 2 and 3, they bottle the spirits they produce.
At premises 2 and 3, they receive and hold spirits produced by a different company for maturation and bottling.
Company A will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce spirits at premises 1 and 2
- approved to hold spirits they produce themselves at premises 1, 2 and 3 without payment of duty
- approved to hold spirits produced elsewhere at premises 2 and 3 without payment of duty
- approved to hold spirits for maturation and package spirits at premises 2 and 3 without payment of duty
Scenario 2 — company B has 1 production premises
At the premises they produce, hold and bottle cider.
Company B also sends some of that cider in duty suspense to a distillery for mixing with spirits to produce a cider-based spirit. The company then receives the cider-based spirits in duty suspense and holds and bottles the product at their premises.
Company B will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce cider at their premises
- approved to hold the cider they produce themselves at their premises without payment of duty
- approved to hold spirits produced elsewhere at their premises without payment of duty
- approved to bottle cider and spirits at their premises without payment of duty
Scenario 3 — company C has 5 production premises
At premises 1, 2 and 3 they produce beer.
At premises 1, 2, 3, 4 and 5 they hold and package the beer they produce in duty suspension.
At premises 4 and 5 they hold and package beer that is produced at 3 different breweries.
At premises 2 they produce cider.
At premises 2 and 4 they hold and package the cider they produce.
Company C will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce beer at premises 1, 2 and 3
- approved to produce cider at premises 2
- approved to hold the beer they produce at premises 1, 2, 3, 4 and 5 without payment of duty
- approved to hold cider they produce at premises 2 and 4 without payment of duty
- approved to hold beer produced elsewhere at premises 4 and 5 without payment of duty
- approved to package beer at premises 2, 3, 4 and 5 without payment of duty
- approved to package cider at premises 2 and 4 without payment of duty
Scenario 4 — company D has 2 production premises
At premises 1 and 2 they receive spirits from 2 different distilleries and rectify those spirits.
At premises 1 and 2 they hold and bottle the spirits they produce (by rectifying).
Company D will require an alcoholic products producer approval (APPA) which will state that they are:
- approved to produce spirits at premises 1 and 2
- approved to hold the spirts they produce at premises 1 and 2 without payment of duty
- approved to hold spirits produced elsewhere at premises 1 and 2 without payment of duty
- approved to package spirits at premises 1 and 2 without payment of duty
Scenario 5 — company E has 3 production premises
At all 3 premises, they import wine which is held in duty suspense.
At all 3 premises they hold casks of spirits for third parties.
Company E will not hold an alcoholic products producer approval (APPA) as no production of alcoholic products is undertaken by the company. Instead, they will be required to hold an excise warehouse approval.
Scenario 6 — company F has one production premises
They receive bulk Scotch Whisky from an approved producer to package. Company F also colour the Scotch Whisky with caramel to prepare the product for bottling strength.
Company F will not need to hold an alcoholic products producer approval (APPA) as no production of alcoholic products is undertaken by the company. Company F will require an excise warehousing approval to receive and package the Scotch Whisky in duty suspension. If Company F were carrying out blending operations or mixing the Scotch Whisky with other alcoholic product, affecting the alcohol by volume or organoleptic properties of the Whisky, they will require an alcoholic products producer approval (APPA).
Scenario 7 — company G has one production premises
They conduct several Scotch Whisky production processes at this site involving fermentation, distillation, maturation and blending.
Company F requires an alcoholic products producer approval (APPA) which will state they are:
- approved to produce spirits at their premises
- approved to hold the spirits they produce at their premises without payment of duty