Details of 2025 WOWGR Changes
As of March 3, 2025, Owners of Warehoused Goods (OWG) have been removed from WOWGR (The Warehousekeepers and Owners of Warehoused Goods Regulations 1999). Prior to this change, HM Revenue & Customs (HMRC) required a mandatory legal review to verify the legitimacy of individuals or businesses owning and storing casks in bonded warehouses.
Impact of WOWGR License Cancellation
With the cancellation of WOWGR licenses, cask holders can now directly hold casks in bonded warehouses under their own name, without going through a commercial entity holding a WOWGR license. Similarly, businesses like Cask Trade no longer need to apply for WOWGR licenses. Businesses and individuals now have equal legal standing.
Impact of Removing “Duty Representatives” Obligations
The requirement for cask holders outside the UK to appoint Duty Representatives has also been abolished. Bonded warehouses can now decide whether they wish to open accounts for overseas businesses or individuals.
Significance of Regulatory Changes for Cask Holders
This change allows cask holders to establish direct accounts with warehouses, including operations such as sampling, regauging, transferring casks, re-racking, or bottling. Some believe this will benefit the whisky cask alternative investment market, as investors can directly hold casks with greater ownership transparency. However, in practice, most warehouses still find it challenging to establish individual accounts for numerous private holders.
As regulated entities, bonded warehouses now bear more legal responsibility and will need to request more comprehensive documentation from businesses and private holders to comply with HMRC regulations. This means more direct relationships between bonded warehouses and cask holders, as well as between HMRC and cask holders. This change helps HMRC better understand supply chain conditions, thereby reducing fraud risks.
Impact on Warehouse Operations
Now, warehouse managers must determine whether to allow individuals or commercial entities (including overseas holders) to open cask storage accounts. Due to increased legal responsibilities and administrative burdens, many warehouses may streamline their operations by no longer accepting private individual accounts.
If warehouses implement these measures, casks sold to individuals without warehouse accounts must be transferred to other locations. However, these changes have also created new business opportunities—warehouses willing to take on additional risks and administrative work can charge fees for private account services. Cask Trade’s bonded warehouse in Speyside will offer this service for an administrative fee of £50.
Future Impact on Delivery Orders (DO)
Delivery Orders (DO) remain standard practice, continuing as the primary form of written record to indicate who warehouses should contact when handling cask movements. Private cask holders must have accounts with bonded warehouses to create and receive DOs.
However, due to increased administrative work and legal responsibilities, many warehouses may be reluctant to open more private accounts. These warehouses prefer working with existing commercial entities to obtain DOs for private cask holders. Therefore, most cask holders will still need to purchase and hold casks through businesses like Cask Trade that already have bonded warehouse accounts.
Cask Trade’s Bonded Warehouse Services
Cask Trade can now provide Delivery Orders to transfer cask ownership to clients who have warehouse accounts. Our bonded warehouse in Speyside can provide DOs for clients’ casks. Additionally, we continue to act as professional custodians managing casks for clients at other warehouses using our warehouse accounts.
Speak to Our Team
If you are interested in buying an entire cask and would like to know more about the details of owning a cask, feel free to contact us for more detailed information.
