Small Cider Producers and AWRS: What Buyers Need to Know in 2025
If a cider supplier has no AWRS number, does that mean they are non-compliant? Not necessarily. Small cider producers cannot register for AWRS because they do not pay duty — and the distinction between producer approval and wholesaler registration matters more than most buyers realise.
In this guide
The old exemption: what it was and why it existed
For many years, small cider makers in the UK operated under a unique exemption. If a producer made less than 5 hectolitres of pure alcohol (hLpa) per year in cider — and produced no other alcoholic products — they were exempt from registering with HMRC as a cider maker entirely. Because they were not registered producers, they also fell completely outside the scope of the Alcohol Wholesaler Registration Scheme (AWRS). They had no Unique Reference Number (URN), and there was nothing to check.
It is worth understanding what 5 hLpa actually means in practice. Pure alcohol production is not the same as total liquid volume. A cider at 5% ABV produces 0.05 litres of pure alcohol per litre of cider. To reach the 5 hLpa threshold at that strength, a producer would need to make around 10,000 litres of cider per year — roughly 10 cubic metres. This covers a wide range of small farm-gate and craft producers.
Note on terminology
The threshold is measured in hectolitres of pure alcohol (hLpa), not hectolitres of cider. This is a common source of confusion. 5 hLpa is 500 litres of pure alcohol — not 500 litres of cider. The equivalent cider volume depends entirely on the ABV of the product.
What changed on 1 February 2025
As part of the wider overhaul of the UK alcohol duty system, HMRC introduced a new unified approval framework for all alcohol producers. From 1 February 2025, every cider maker — regardless of how much they produce — is now required to hold an Alcoholic Products Producer Approval (APPA) from HMRC. The old sub-5 hLpa exemption from production registration no longer applies.
HMRC is explicit on this point. Their guidance states: "If you're a cidermaker you'll need to apply for an APPA, even if you were exempt from seeking approval before, or produce less than 5 hectolitres of pure alcohol in cider and no other alcoholic products."
Producers who were already registered with HMRC before February 2025 had their existing registrations automatically migrated to a single APPA. Previously exempt producers who had not registered had to apply for a new APPA. The National Association of Cider Makers (NACM) advises its members to include their APPA number on all invoices as proof of their approved producer status.
Important
The August 2023 alcohol duty reform changed duty rates and introduced Small Producers Relief — but it did not change registration requirements for cider makers. The registration change came later, on 1 February 2025, when the APPA framework came into force.
Why small cider producers cannot register for AWRS
This is a critical point that is often misunderstood. Small cider producers operating under the sub-5 hLpa threshold do not just lack the need to register for AWRS — they cannot register for it. AWRS registration requires a business to be paying excise duty on the alcohol it sells. Small cider producers under the threshold have zero duty liability, which means they are ineligible for AWRS registration entirely.
This matters because it means a "not found" result for a small cider producer is not a sign of non-compliance or evasion — it is the expected and correct outcome. There is no URN to find because there is no mechanism for them to obtain one. As a buyer, you cannot hold this against them. What you can and should do is verify their APPA status instead.
APPA vs AWRS: two different regimes
This is the most important distinction to understand — and the one most commonly confused.
APPA (Alcoholic Products Producer Approval) is a production registration. It is required by anyone who manufactures alcoholic products in the UK. It proves HMRC has approved the producer as a legitimate, fit and proper business. Having an APPA does not mean a business sells alcohol wholesale.
AWRS (Alcohol Wholesaler Registration Scheme) is a wholesale trading registration. It applies specifically to businesses that sell alcohol to other businesses (B2B) for onward sale or supply. It is the registration you need to verify as a buyer — but only where the supplier is eligible to hold it.
The two are entirely separate. A cider maker with an APPA is not automatically on the AWRS register, and a small cider producer paying no duty cannot be on the AWRS register at all. A small craft cidery selling directly to a farm shop or trade buyer is acting in a B2B capacity, but if their duty liability is zero, AWRS simply does not apply to them.
| Registration | Who needs it | Verifiable in AWRSCheck? |
|---|---|---|
| APPA | Anyone who produces alcohol | No — no public HMRC lookup exists |
| AWRS | Anyone who wholesales alcohol B2B and pays duty | Yes — this is what AWRSCheck verifies |
What a "not found" result actually means
When AWRSCheck (or HMRC's own look-up tool) returns no result for a supplier, it means one of two things:
1. They are not registered as an AWRS wholesaler
This is the most common reason. The supplier is not on the AWRS register. If you are buying alcohol from them for onward sale and they are a duty-paying wholesaler, this is a compliance problem — and you should not purchase from them until they can demonstrate their registration.
2. They are a small cider producer with no duty liability
A small cider producer operating under the duty threshold cannot register for AWRS, because AWRS registration requires paying excise duty. A "not found" result for these suppliers is expected and correct. They should instead provide their APPA number as proof of their approved producer status — and the NACM advises its members to include this on all invoices.
Note on APPA verification
Unlike AWRS, there is currently no public HMRC lookup tool for APPA numbers. The planned online service was scrapped before launch. This means APPA verification is currently trust-based — you ask the supplier for their 15-digit APPA ID and take it on good faith. This is a known gap in the compliance framework and something the industry is aware of.
How to handle due diligence for cider suppliers
If you buy cider from a supplier who appears on AWRS, your due diligence process is the same as for any other supplier — check their URN, record the result, repeat regularly.
If a cider supplier has no AWRS URN, here is what to do:
Ask for their APPA number
All cider makers must now hold an APPA. Ask the supplier for their APPA ID — a 15-digit reference issued by HMRC. The NACM advises members to include this on all invoices. If a supplier cannot provide an APPA ID, that is a serious concern regardless of their size or claimed exemption status.
Check whether their "not found" result is expected
If they are a small cider producer with no duty liability, a "not found" AWRS result is the correct outcome — they are ineligible to register. If they are a larger producer or a conventional wholesaler of any alcohol type, "not found" means they are not registered and you should not be purchasing from them.
Document everything
Keep a record of the AWRS check result, the supplier's APPA ID as provided on their invoice or in correspondence, and any explanation they give for not appearing on AWRS. This paper trail is your evidence of due diligence if HMRC ever questions a transaction.
AWRSCheck tip
When AWRSCheck returns a "not found" result, it means the supplier is not on the AWRS wholesaler register. This is correct behaviour — the tool is working as intended. For small cider producers with no duty liability, this is the expected outcome. Ask for their APPA number, note it alongside the check result, and keep both on file.
Sources
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