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A Primer On WOWGR and Revenue Traders

WOWGR – an acronym for the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 – is the law that must be followed by Warehouses, Warehousekeepers and owners of goods kept in UK warehouses. Despite rumours that it soon will be repealed, for now it remains a legal pillar governing cask storage.  

Think of it as a registry that includes warehousekeepers, cask owners without a warehouse and duty representatives, amongst others, whose applications are approved. 

Must an individual or entity that decides to purchase a cask register under WOWGR? The simple answer is ‘yes’ – but only for revenue traders. 

What is a revenue trader?

Regarding cask ownership, revenue traders are defined in Excise Notice 206: revenue traders’ records, and in the glossary of Excise notice 196.

• Excise Notice 206 defines a revenue trader as “involved in any way with goods or services liable to Excise Duty”;

• Excise Notice 196 section 13 also defines a revenue trader “in the context of this notice, anyone carrying on a trade or business concerned with the buying, selling, importation, exportation, dealing in, or handling of excise goods, and the financing or facilitation of any such transactions or activities. Find a full definition in CEMA section 1.”

A revenue trader is, therefore, a trade, trader, or business involved in casks. The following flowchart helps determine whether a person or entity purchasing a cask must apply for registration under WOWGR.

Do I Need A WOWGR Flow Chart

Owning more than five casks

Owning five casks or fewer is the unofficial threshold considered by many legal experts and industry figures as the reasonable limit of what could be classed as ‘personal consumption.’ Ownership of more than five casks could be considered as beyond personal consumption and means the owner may be classed as a revenue trader and must apply for registration under WOWGR. It is possible to own more than five casks as a private individual but the casks’ owner would need to justify their reasoning to both the warehouse holding the casks and HMRC.

Regularly buying and selling casks

Even when you own fewer than five casks, if you are regularly buying and selling casks to make a profit that supplements your income you could be classed as a business and must apply as an owner under WOWGR

Buying casks via a business bank account?

If Scotch whisky casks are being bought and sold through a business bank account, then HMRC will likely assume the whisky is being used for business purposes and therefore consider the entity a revenue trader. For individuals and entities not planning to become revenue traders, it is highly recommended to use a personal bank account for the relevant transactions. 


The information provided on Protect Your Cask is intended solely for educational and informational purposes and does not constitute legal, financial, or investment advice. We strongly encourage readers to conduct their own research and, where necessary, consult with professional advisors or legal counsel before making any investment decisions in the Scotch whisky cask market. The views and opinions expressed herein are not intended to serve as a guarantee or prediction of future events and should not be relied upon as such. Protect Your Cask disclaims any liability for decisions made based on the information provided on this website.