Retail & Consumer Goods UK-wide

Wholesale compliance checklist

A confirmation checklist for wholesale businesses. Work through the cross-cutting duties every wholesaler shares, then the section for what you trade — controlled and excise goods, general merchandise, food and agricultural goods, or waste, scrap and fuel. You may need more than one section.

Guide summary

Start with the duties that apply to every wholesale business — health and safety, fire assessment, data protection, discrimination, insurance, and waste. Then complete the sections for the goods you trade: alcohol and tobacco, medicines, general merchandise, food and agricultural goods, or waste and fuel. You may need more than one section.

  • Manage warehouse safety under health and safety law
  • Carry out a fire risk assessment based on your stock
  • Pay the ICO data protection fee unless exempt
  • Hold employers' liability insurance of at least £5 million
  • Follow waste rules: store, describe and transfer correctly
  • Register for AWRS before selling alcohol wholesale
  • Check alcohol and tobacco are duty-paid or duty-suspended
  • Join tobacco track-and-trace system
  • Register your food business with the local authority 28 days early
  • Register as a waste carrier if you transport, buy or sell waste
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Related guides in General Compliance

Confirm the obligations that apply to your wholesale business are in place. Start with section 1, which applies to everyone, then complete every section that describes what you trade — you may need more than one. Where a duty differs by nation, the item says so.

Section 1 — Every wholesale business

  1. 1

    Manage warehouse health and safety

    Control racking, forklift, loading-bay, manual-handling and working-at-height risks under the Health and Safety at Work etc. Act 1974 (Great Britain, with equivalent rules in Northern Ireland).

  2. 2

    Assess fire safety

    Carry out and maintain a fire risk assessment of your warehouse or depot, accounting for flammable and combustible stock (Fire Safety Order in England and Wales, separate regimes in Scotland and Northern Ireland).

  3. 3

    Pay the ICO data protection fee

    Unless exempt, register and pay the ICO fee and handle trade-customer and staff data under the UK GDPR. Applies UK-wide.

  4. 4

    Avoid discrimination

    Comply with the Equality Act 2010 (Great Britain) or Northern Ireland equality law in employment and business dealings.

  5. 5

    Hold employers' liability insurance

    At least £5 million cover from an authorised insurer if you employ anyone (Great Britain, with equivalent rules in Northern Ireland).

  6. 6

    Meet your waste duty of care

    Store, describe and transfer waste correctly with transfer notes, to authorised persons only. Devolved regulators (EA, NRW, SEPA, NIEA).

Section 2 — Controlled and excise goods (alcohol, tobacco, medicines)

  1. 1

    Register for AWRS before wholesaling alcohol

    HMRC approval under the Alcohol Wholesaler Registration Scheme, with a URN, before you trade — including brokers. Verify your suppliers' URNs. UK-wide.

  2. 2

    Account for alcohol and tobacco excise duty

    Hold only duty-paid or properly duty-suspended stock. Operate EMCS for duty-suspended movements. Tobacco must bear UK fiscal marks.

  3. 3

    Join tobacco track-and-trace

    Obtain Economic Operator and Facility IDs, scan unique identifiers and record movements. UK-wide.

  4. 4

    Hold a Wholesale Dealer's Authorisation for medicines

    WDA(H) from the MHRA for human medicines, or a VMD authorisation for veterinary medicines, with Good Distribution Practice and a Responsible/qualified person. UK-wide.

  5. 5

    Register as a medicines broker if you broker without stock

    If you arrange medicines sales without holding the stock, hold separate MHRA broker registration in addition to, or instead of, a WDA(H). UK-wide.

  6. 6

    Get a Home Office licence for controlled drugs

    A controlled-drugs domestic licence in addition to the WDA(H), with secure storage and record-keeping. UK-wide.

Section 3 — General merchandise (distributor duties)

  1. 1

    Verify conformity before you supply

    Check products carry the required marking (UKCA, or CE where still accepted on the GB market), labelling and documentation for their category — chemicals, electrical goods, machinery, construction products, textiles, furniture, cosmetics, precious metals.

  2. 2

    Store and handle goods correctly

    Do not let storage or transport conditions compromise a product's conformity or safety.

  3. 3

    Keep traceability records

    Record who you bought from and supplied to so unsafe goods can be traced both ways. Act on recalls and enforcement.

  4. 4

    Do not supply unsafe or non-compliant goods

    Meet the General Product Safety baseline and the sector-specific product-safety rules. Do not supply products you know or suspect are dangerous. OPSS and Trading Standards enforce.

Section 4 — Food and agricultural goods

  1. 1

    Register your food business

    Register a food storage or distribution business (including cash-and-carry) with the local authority at least 28 days before opening. Free. UK-wide (devolved food hygiene regulations).

  2. 2

    Get approval for products of animal origin

    Cold stores and meat-handling premises generally need approval (not just registration) under Regulation 853/2004, with an approval number.

  3. 3

    Keep food traceability and HACCP records

    One-step-back/one-step-forward traceability and HACCP-based procedures proportionate to a storage and distribution operation. Be able to withdraw or recall unsafe food.

  4. 4

    Meet animal, feed and plant controls where relevant

    Feed-business registration, animal by-products controls, plant passport registration, and transporter authorisation and movement/disease controls for live animals (APHA, with devolved variants).

Section 5 — Waste, scrap metal and fuel

  1. 1

    Register as a waste carrier, broker or dealer

    If you transport, buy, sell or arrange the disposal or recovery of waste. Hold an environmental permit or exemption if you store or treat waste at a site. Devolved (EA, NRW, SEPA, NIEA).

  2. 2

    Get a scrap metal dealer licence

    A site or collector's licence from the local authority, verifying seller identity, with no cash purchases. Scrap Metal Dealers Act 2013 (England and Wales). Civic Government (Scotland) Act 1982.

  3. 3

    Control fuel storage and dangerous substances

    Bunded secondary containment for oil storage, and DSEAR risk assessment and controls for flammable fuels. Bulk storage above thresholds engages COMAH.

Related guides

The guides this checklist confirms.