UK Abolishes 24 Year Whisky Regulation Transforming Cask Ownership

WOWGR has been updated. In the words of Alan Powell, the man who has tirelessly spearheaded the campaign for updates, “the clock will be reset to October 1999 since there was never any justification for the “ownership” part of the regulations.” It means that casks of scotch whisky held in bonded warehouses are now treated in line with the likes of wine and fuels, and can be held by individuals and businesses without going through lengthy registration.

It is an important update for the industry, as it removes some of the bureaucratic strain placed on whisky owners, from warehouses and business to private individuals. Privately owned casks are a small part of the multi billion dollar scotch whisky industry, but the updates will have important benefits for those owners too.

What Is WOWGR?

WOWGR stands for The Warehousekeepers and Owners of Warehoused Goods Regulations 1999, which is UK Statutory Instruments 1999 No. 1278. It was introduced in the UK in 1999 because of concerns over tax fraud within some duty suspended goods, specifically whisky, beer and tobacco.

Until March 2025 WOWGR acted as a register with HMRC to prevent fraud. All warehousekeepers and owners of warehoused goods that were revenue traders had to get permission to own, store, move and trade those goods. This included overseas businesses, who had to register via a UK based Duty Representative, which was also governed by WOWGR.

The March 2025 updates essentially remove the OWG (owners of warehoused goods) section so that only warehousekeepers need to register, and bring the storage of whisky casks in line with wine and petrochemicals. The updates remove the need for businesses (other than those with their own warehouse and warehousekeeper) to go through the lengthy registration process. The updates also remove the need for duty representatives for overseas owners.

Why Was It Repealed?

By the early 2020s large scale tax fraud from the goods covered under WOWGR had been virtually eliminated. The industry feedback from WOWGR showed growing frustrations around the scheme that only covered around half of warehoused products (wine and fuel were excluded). In late 2022 HMRC concluded that the owner-registration part of WOWGR was no longer proportionate or effective​ and that it should be repealed.

Powell discussed the changes to me over an email, “the change to the regulations that I have been campaigning for the last few years will remove the disproportionate impositions for beer and spirits which were also always in breach of (retained) EU law and are obviously discriminatory—alcohol products being treated differently for no objective reason.”

WOWGR And Fraud

WOWGR was introduced in the UK because in the 1990s it was estimated that hundreds of millions of pounds of duty had been defrauded through export of duty suspended beer, whisky and tobacco. Over the following two decades WOWGR helped to reduce this to almost nothing. However, while WOWGR helped to prevent large scale tax evasion, throughout the 2010s the registration scheme had increasingly become used by firms selling casks to the public as a reason not to transfer full ownership to the buyer.

WOWGR specifically covered revenue traders—i.e. businesses—and private individuals buying a small number of casks never needed to register. However this explanation was buried within the long and complex piece of legislation. That meant unscrupulous cask sellers could present WOWGR as a reason as to why they weren’t transferring casks fully into the buyers names.

There are some cases where non-transfer is benign. But largely speaking where I have been contacted by people who want help with issues around casks they have bought, the issues stem from not owning their casks at the warehouse level. And usually they have been told they can’t own them fully because of WOWGR.

What WOWGR Changes Mean For Cask Owners?

From independent bottlers to overseas investors, the removal of the bureaucratic barrier of WOWGR is significant. The updates will help small businesses and even private individuals who want to get involved in buying and owning multiple casks of scotch whisky.

While privately owned casks are a small part of the multi billion dollar scotch whisky industry it is a growing industry. One company alone claims to have $90,000,000 (£70,000,000) worth of casks held by private individuals and that is with the barrier of WOWGR. Now that the lengthy registration issues aren’t needed, it should open up scotch whisky cask investments for more people and businesses who love, and can stimulate, the industry.

“It’s great that the owners now have full control over their casks, with direct access to the warehouses,” explained Charles Costello, of Volpe & Costello who provide warehouse storage and bottling to both business and private cask owners. “However, the real question is whether the warehouses will adapt to this shift and allow accounts to be opened, regardless of the number of casks.”

Just as importantly, the changes mean that unscrupulous cask sellers cannot hide behind WOWGR as an excuse for why they won’t transfer a cask into a client’s name. If the reason is that they don’t have a warehouse that will open private accounts then they will have to be honest and give potential customers the information they need to make an informed decision.

There may be some additional burden on warehousekeepers initially, but they had to have records of casks and owners anyway, and were already required to do due diligence checks before opening accounts. Overall I think that the changes will be positive for the industry both at the business and private investor levels.