1. The Black Pearl Distillery Ltd – Strategic Core & Wholesale Hub

• Manufacturing Powerhouse: The Black Pearl Distillery Ltd is the principal manufacturing entity within the group, specializing in gin and rum production. It holds the Alcohol Producer and Packager Approval license, authorizing large-scale production and packaging of alcoholic spirits.

• Wholesale Driver: The Black Pearl Distillery Ltd also holds the Alcohol Wholesaler Registration Scheme license, enabling it to legally sell alcoholic products to other businesses. This forms the backbone of the group’s business-to-business wholesale operations.

• Internal Supply Chain Leader: The Black Pearl Distillery Ltd supplies suspended duty ethanol to affiliated entities. This duty-suspended supply chain allows for efficient internal transfers, with excise duty only applied upon release for consumption, optimizing cash flow and compliance.

• Brand Ownership and Strategic Control: The Black Pearl Distillery Ltd is the registered owner of the City of Liverpool Gin and City of Chester Gin brands. These gins are now produced by a commercial distiller under an outsourcing agreement and sold under The Black Pearl Distillery Ltd’s brand umbrella. The Black Pearl Distillery Ltd retains majority shareholding and strategic oversight across all entities, ensuring brand consistency and regulatory alignment.

• Production Vessels and Bottling: Gin and rum are produced by a commercial distiller in 1,000-litre Intermediate Bulk Containers (IBCs) under suspended duty, contingent upon successful Alcohol Producer and Packager Approval licensing. Bottling occurs at The Black Pearl Distillery Ltd in 70cl and 5cl miniature formats. Gin is distributed to collaborative brand partners under the City of Liverpool Gin and City of Chester Gin labels, while rum remains a core product of The Black Pearl Distillery Ltd.

2. Upcoming Micro-Distilleries – Expansion of Craft and Experiential Sales

• Strategic Growth: The group plans to launch three new micro-distilleries focused on small-batch gin and rum production. These sites will emphasize a “still to consumer” model, offering on-site distillation, direct sales, and immersive brand experiences.

• Licensing Approach: These micro-distilleries will operate under personal licenses and premises licenses, enabling direct sales without requiring Alcohol Wholesaler Registration Scheme or Alcohol Producer and Packager Approval licensing for each site.

• Premium Positioning: These locations will support premium product development, experiential marketing, and community engagement, reinforcing the group’s artisanal ethos.

Group Synergies and Vertical Integration

• Controlled Supply Chain: The Black Pearl Distillery Ltd’s centralized ethanol supply ensures consistent quality and compliance across all production entities.

• Cost Efficiency: Internal transfers of ethanol and finished products reduce reliance on external suppliers, improving margins and operational control.

• Market Diversification:

  • Wholesale: The Black Pearl Distillery Ltd targets trade customers such as hotels and restaurants.

• Brand Differentiation:

  • City of Liverpool Gin and City of Chester Gin are distinct brands under The Black Pearl Distillery Ltd’s ownership, each with its own local identity.

  • Rum remains The Black Pearl Distillery Ltd’s core manufacturing focus.

• Optimized Licensing Strategy:

  • The Black Pearl Distillery Ltd holds Alcohol Wholesaler Registration Scheme and Alcohol Producer and Packager Approval licenses for wholesale and manufacturing.

  • Micro-distilleries operate under personal licenses for direct retail.

  • This structure ensures regulatory compliance while supporting scalable, craft-focused operations.

• Innovation and Agility: The micro-distillery model allows for rapid product development and consumer engagement without disrupting core operations.

Conclusion

The Black Pearl Distillery Ltd has established a vertically integrated, multi-brand ecosystem that balances regulatory compliance, operational efficiency, and market reach. By distinguishing its wholesale and manufacturing hub from its craft gin brands—now produced by a commercial distiller under outsourcing agreements—the group demonstrates a clear, compliant, and strategically optimized structure for HMRC review.