What WOWGR Updates Mean For Scotch Whisky Cask Investment

A major update to the scotch whisky industry has been announced. WOWGR updates from March 2025 will essentially change the “Warehousekeepers and Owners of Warehoused Goods Regulations 1999” to just the “Warehousekeepers Regulations.”
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Changes to WOWGR in 2025 will bring the ownership of duty suspended beer and spirits, including whisky casks, in line with other assets like wine and oil. Photo: Mark Littler Ltd

A major update to the scotch whisky industry has been announced. The long awaited WOWGR updates will come into effect in March 2025, essentially changing the “Warehousekeepers and Owners of Warehoused Goods Regulations 1999” to just the “Warehousekeepers Regulations.” It marks an important transition for the scotch whisky cask investment industry.

The important changes bring spirits and beer in line with the regulations for items like wine and oil. For scotch whisky casks it essentially means private owners won’t need to go through the lengthy registration process to buy, sell and trade scotch whisky casks. This will hopefully stimulate the burgeoning whisky cask investment market. However there are some issues that may arise as well, we’ll break it all down below.

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What Has Changed With WOWGR Updates?

In a nutshell, “WOWGR” (Warehousekeepers and Owners of Warehoused Goods Regulations 1999) will change to “WR” from March 3 2025 and will just govern Warehouskeepers. It is essentially resetting the clock to 1999 when the UK tax body HMRC (HMCE as it was known then) introduced regulations on non-businesses trading duty suspended goods because of concerns about tax evasion. Wine and oil industries lobbied for exemptions and got them, but for beer and spirits the private ownership industry was small and so they didn’t do the same.

From March 2025 this discrepancy will be removed and only Warehousekeepers will be able to/required to register. Owners who are not specifically Warehouskeepers won’t be able to be certified, this includes both private individuals and businesses.

What the changes mean to you depends on how you own your casks; full ownership through a delivery order versus secondary ownership via someone else’s WOWGR.

If You Own A Cask Through A Delivery Order

If you have an account at a warehouse and own casks of scotch whisky through a delivery order then the WOWGR updates are positive. For UK based private owners there is now no five cask limit and you can buy and sell casks without worrying about becoming a revenue trader. For private cask owners outside the UK then not much changes as WOWGR never applied to you.

If you are a non-UK based business owning casks at a warehouse with a Duty Representative then you should contact your Duty Rep to ensure they will still be able to represent you after March 2025. Only Warehousekeepers will be able to register under the amended regulations, as such if your Duty Rep was an “Owner” rather than a Warehousekeeper, they may not be able to represent you going forward.

Owning Casks Through A Businesses With A WOWGR

A lot of cask investors do not own their casks directly, but instead own them through a business that has its own WOWGR certification. If you didn’t get a delivery order and received a “certificate,” “deed,” or something similar that was not issued directly by the warehouse then you probably own your cask through a company. It may be the dealer you bought from, or it may be a third party WOWGR holder.

The five cask limit for UK based private owners is removed. For private cask owners outside the UK then not much changes as WOWGR never applied.

If the WOWGR certified business is an “Owner” rather than a “Warehousekeeper” then their WOWGR certification will not be valid from March 3 2025. It is likely that you will still be able to own the cask via that company, but you should be aware that they are now completely unregulated—the slim amount of certification provided by WOWGR will be gone. As such you may wish to request that they transfer the cask into your name at the warehouse.

If the business you purchased through had misinterpreted the old legislation and told you that you could not own casks directly without a WOWGR, then you will now be able to contact them to find out their plans following the changes. The updates mean that companies will no longer be able to mislead (knowingly or otherwise) purchasers into thinking they cannot own a cask directly.

While the changes to WOWGR are welcome, unfortunately there may still be issues with getting casks directly into customers’ names.

Warehouse Limitations

The WOWGR updates are a welcome simplification for those in the scotch whisky cask investment industry and remove the ability for rogue companies to mislead customers about ownership. Unfortunately the reality of why companies switched to indirect ownership remains.

You can only own a cask directly if the warehouse where it will be stored will open you an account. Dealing with hundreds of private owners is significantly more hassle (and more costly) than dealing with a handful of business owners, and so warehouses stopped offering new accounts to private owners. There are a handful of warehouses that will open private accounts, but the vast majority do not.

Dealers who work with warehouses that will not open accounts for private customers started doing internal transfers instead. The casks technically remain in their name at the warehouse and they provide other documentation for their customers to prove ownership. In some cases this is fine, but it has also proved problematic where dealers have not been legitimate.

The changes to WOWGR will likely not change warehouses’ views on private accounts. So whether all dealers will be able to transfer the cask into their customers’ names following the changes remains unclear.

Scotch Whisky Cask Investment Remains Unregulated

Cask investment has always been unregulated and WOWGR did not provide regulation for the cask investment industry. For businesses that wanted to become “owners” it was essentially just a drawn out registration scheme with HMRC.

WOWGR did provide a small barrier for entry for any unscrupulous business that wanted to sell casks. That barrier is now gone. As such, doing your own due diligence when looking at working with cask investment companies remains the top priority for anyone looking into scotch whisky cask investment.

Hannah Thompson

Hannah Thompson is a whiskey investment educator who helps consumers understand everything they need to know to make an informed decision about whiskey investment. She has been working in the secondary whiskey market since 2019 and joined The Whiskey Wash team when Mark Littler took over as Editor in Chief. Working with Mark Littler Hannah has amassed a broad range of whiskey knowledge and specializes in helping consumers make education driven cask investments. Hannah has authored two published works of fiction and her background in research and creative writing lets her create interesting and informative articles to give people a solid understanding of the world of whiskey.

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