Brewing Syndicate - do regs apply?

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Dave Parry

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Shrewsbury, Shropshire
I’ve been brewing on my 20 L set up for a couple of years and I’m now thinking of upgrading to a 1 bbl nano-brewery system by joining forces with a few brewing friends.

The plan will be to all chip in an equal amount to buy the equipment and then just split the cost of ingredients. We will each take an equal share of the produce for personal use.

I am working on the assumption that even with 10-20 syndicate members (top end), this still falls outside of the remit of all of the regulations (HMRC, planning, local authority, sewage discharge permits etc).

Before I proceed and to get too many more friends excited about it though, I thought I’d better check on here to see if that is the case.

Does anyone have a view? Or should I start ringing all of the relevant authorities and ask them directly?

Thanks for any help.
 
Apart from the regulations there are the insurances you need, and sanitary requirements (washable floor etc.). There are some threads on here from brewers that went that way (https://www.thehomebrewforum.co.uk/threads/hmrc-registration-not-so-daft-an-idea-after-all.10910/ for instance), to me it looks quite a pain to set up but once it's running, it's running.

Thanks GerritT. Just to be clear on my question, I’m not trying to set up any more than a normal home brew set up (ie no need for washable floors, insurance etc).

I just want to share the costs of a larger home brew kit amongst friends and we all use the same kit, on the same basis as if we had our own individual kit.

Do you think it is the very act of sharing kit which brings it to the attention of the regulatory authorities?
 
If you're not selling anything, none of the regulatory bodies will care.

Am I right in assuming the kit is going to be at your house? If so, I can't see why friends coming round to brew would be a problem: legally speaking. What I would find a problem is 10-20 people wanting round to my house to brew on the kit...

You do realise that if you have 10 - 20 people in a brewing syndicate, who want to brew regularly, you're going to need an enormous amount of space for fermenters. An unfeasible amount of space... Unless your buddies are going to cart 100L+ of beer away with them after each brewday?
 
My nearest homebrew shop has installed a 100l system which you can hire on site to brew your own beer ..
In an ideal scenario they could hire it out twice a day,5 days a week...so a 1000l a week. Would this be a similar situation? Why do you need to register,declare anything as it's only for personal use?
 
Good point Ghillie...how would water and gas/electric be worked out...? You would also have quite a lot of stuff to dispose of.

I'd imagine you'd be looking at disposal of around 30kg (wet weight) of grain at each brew? So assuming that each brewer is going to take their 120L+ of beer away with them AND 30kg of wet grain. That's a minimum of 150kg in the back of the car alone :laugh8:

Because of that, I'm out!
 
Not unless you done 5 kits at a time..also would it be the case where you would have someone who doesn't quite do everything to the same or required standard so someone would cop for extra cleaning..
I really think this is a nest of rats of an idea. I once tried a baiting campaign for carp fishing which involved making bait (boilies) from scratch,sourcing ingredients,mixing,storing around 100kg at the start,to make it viable. Then gas burner,rolling table and freezer space. Plus regular trips to the lake baiting up etc. It does pay dividends,you catch. But...it's no good when your "partner" can't have any at his house because his Mrs won't let him,doesn't like the smell,can't go to the lake,can't be arsed,tell you what..YOU make it all and I'll have half....no thanks!
 
if you were going to share each others brews at least 6 way then thats only 20kg and if you do the same with the grain its 5kg or a bag of cement for them both, much more manageable its not like all 10-20 people would turn up the same time. Yes 150kg of beer stuff taken away is only 2 x 75kg passengers but image a 120 litre beer spillage incident asad.

hmm.... warrior pick up truck...

https://www.tanks-direct.co.uk/wate...water-tanks/140-litre-upright-water-tank.html

nice!
 
All good points everyone. Let me try to cover a few of them:

My house?
Possibly. Probably Plan A, but if we had someone come along with a nicer outbuilding or barn it might be better. This is SHREWSBURY and everyone has a reasonable amount of space. I’ve got a double ‘tandem’ garage and could use the back one, which is where I have my set up at the moment.

10-20 visiting regularly?
Given that the output is for personal consumption, I can’t imagine we are going to be doing more than one or maybe two brews per month and not everyone needs to be there for every brew – maybe three or four people at a time. Some are more interested in brewing than others, some are just interested in having their share of the output.

Space for FVs?
We will probably only have one 200 L fermenter and I think we could fit one of those in. This would limit us to 2 brews per month, but I think this is plenty to start with.

A lot to carry away?
This spent grain could weigh even more than you suggest, and I hadn’t thought of that. I currently feed mine to my chickens, but they wouldn’t get through that much! As for the liquid output, I’m not imagining they take away the wort, but just their share of the finished product. To avoid lots of bottling, I am going to suggest that everybody has a 10 L stainless steel mini keg which you can get for around £100 with beer spear, tap and CO2 cylinder attachment.

Electricity costs?
Once again, easy to ignore when you are only used to brewing smaller batches, thanks. I imagine that like the ingredients this will be divided between all members and paid for upfront.

What do you think? Does this still sound like homebrew to you/HMRC? It’s definitely not for sale or distribution to the general public or any other form of commercial gain. It’s just a way of getting a group of like-minded people together, get more people interested in brewing, and to get access to much sexier kit then we could afford/would need on my own.
 
Good point guys, I was barking up the wrong tree. I had visions of each of the 10-20 participants wanting to make their own 1BBL batch. i.e. 10-20 FV's trying to find a space in the shed! Splitting things would mean that the spent grains could easy be taken home by each person and fed to chickens, composted, binned, etc.

Going from what the OP has suggested, it's not as much of a write off as I initially thought. Quite doable in fact.

As home brewing is perfectly legal as a hobby, providing no money changes hands and it's for personal consumption, I would imagine that if all parties were "involved" in the process somehow then you could argue the beer is personal to everyone...

IMO, the HMRC won't care. Even better, what they don't know won't hurt them. HMRC have one purpose, and that is to extract money from people making money. If you're not making money, they will not be interested. Environmental health may be a different story though. They may take the angle that "this is your property and you're effectively giving your beer to the others" - so premises still needs to be fit for purpose. Again, what they don't know won't hurt them.

@Dave Parry - if traditional ales are your tipple, like the cask conditioned stuff, then you could literally turn a brew round in 6 days or less.
 
Thanks @Ghillie, appreciate your comments. I was beginning to think I was the only one that had seen sense in it for a moment. I’m just surprised that despite quite a lot of searching on the Internet (as you can imagine), I have not found any examples of other people doing something similar. I did wonder whether the “Men’s Sheds“ movement might have tried something, but if they have then they are not shouting about it.

I would imagine getting all syndicate members to sign agreements to confirm that they will be following the various rules. I have been in a boat owning syndicate for nearly 20 years which has worked okay and I know that syndicate models work well with other hobbies that are expensive (flying for example).

I did have a question which is a legal one which is to do with the liability if a member of the syndicate decides to break the rules and try to sell any.
 
I don't see too many problems with it as long as the all the people are involved in the brewing of said beer. I also think as pointed out the HMRC are only interested in profit making and tax avoidance/evasion so that should be ok however the local council/enviroment may have something to say regards the so called effluent that is washed down the drains as it is more than a normal amount but I would not worry too much on that count unless you have a local neighbourhood busy body who may dob you in
 
I did have a question which is a legal one which is to do with the liability if a member of the syndicate decides to break the rules and try to sell any.
If I were you and had potential doubts where I felt the need to go down the road of signed contracts, etc. Then a venture like this is absolutely not something I would wish to start up or get involved with...

The concept is a fairly good one, but like a lot of things it's sometimes best to just do it yourself. Too many cooks spoil the broth and all that. You could have nineteen good guys and one arsehole. It just takes one person to ruin something good.

A means to totally mitigate that risk is by keeping it a one man operation. That way, if you do find that there is an arsehole involved who is out to make things difficult, then you only have yourself to blame:laugh8:
 
If I were you and had potential doubts where I felt the need to go down the road of signed contracts, etc. Then a venture like this is absolutely not something I would wish to start up or get involved with...

The concept is a fairly good one, but like a lot of things it's sometimes best to just do it yourself. Too many cooks spoil the broth and all that. You could have nineteen good guys and one arsehole. It just takes one person to ruin something good.

A means to totally mitigate that risk is by keeping it a one man operation. That way, if you do find that there is an arsehole involved who is out to make things difficult, then you only have yourself to blame:laugh8:
I think Ghillie is right it only takes one later down the line to want his share back out later or your not brewing what they want to spoil it. A good idea but putting it into long term action is another thing
 
The wording regarding exemption in Excise Notice 226 is:

  • brewing solely for your own domestic consumption.
The likelyhood is HMRC will never know. However, if they do take an interest, there are penalties for not being registered. Even though you'd not be making money, they could view it as a way of tax avoidance if you were brewing for a number of people.
I guess this is normally enough to put most people off doing this.
 
All wise words of advice, so thank you very much for those. I’m already passed the stage of worrying/wondering whether I want to do it in principle as I’ve been talking about it with my friends for awhile. I know who would be involved and I know that no one fits the category you describe! This is something to do amongst a bunch of mates.

I’m fairly relaxed about the idea of getting agreements signed and so on. I’m also pretty keen to try something new to see if it works. What’s the worst that can happen assuming it is all legal, decent and honest? Maybe there would be a secondhand mini brewery on eBay in a couple of years time? Not the end of the world. I’ve started a couple of businesses, and some have worked and some haven’t. It’s what makes life interesting.

The purpose of this thread was initially to seek the collective wisdom of the forum members on the regulatory technicalities. Your responses have all been very useful on that front, as too have the responses on the general words of caution and on the practicalities of scaling up.

Thank you everyone. It’s my first thread on this forum and I’m very grateful for everybody’s help. If I manage to get it off the ground then I will be sure to post back on progress for general interest.
 
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