Keeping records for Vaping Products Duty and the Vaping Duty Stamps Scheme
Find out what records you need to keep for Vaping Products Duty and the Vaping Duty Stamps Scheme.
Who this applies to
These requirements apply to anyone who manufactures, imports, stores, moves, stamps or supplies vaping liquids (vaping products) in the UK, including UK representatives acting for overseas manufacturers.
How long you must keep records
You must keep all records and supporting evidence for at least 6 years. Records must be complete, legible, and retrievable without delay.
If you use electronic systems, you must be able to export data in a readable format on request.
General records you must keep
You must keep general business and duty records that show how you have handled vaping products and worked out the duty you owe, including:
- a duty account showing how you calculated the Vaping Products Duty you owe for each accounting period, including adjustments and repayments
- stock records that identify receipts, holdings, operations and dispatches of vaping products, showing dates, quantities (net liquid volume), duty status, and locations
- movement records for goods held or moved in duty suspension (including warehouse references and movement documents)
- copies of returns and payments, including working papers that support the figures declared
- an auditable trail linking production, purchases, imports and movements to sales, exports, destruction and duty declarations
Additional records specific to Vaping Products Duty and the Vaping Duty Stamps Scheme
You must also keep extra records that relate specifically to Vaping Products Duty and the Vaping Duty Stamps Scheme, including records about the following.
Production and measurement
You must keep a record of:
- batch records for all liquids produced
- inputs (propylene glycol or vegetable glycerine, nicotine, flavourings)
- yields and losses
- calibration certificates and checks for tanks, fillers and measuring equipment
- evidence that net liquid volume has been determined and reconciled to labels and invoices
Stamp lifecycle
You must keep a record of:
- orders or receipts of stamps
- secure storage logs
- activation data
- application logs (date and time, operator, line, premises, product and batch)
- scanning events at required points
- returns or credits of unused or spoilt stamps
- records of lost, stolen or damaged stamps and incident outcomes
Stamped product inventory
You must keep a record of:
- reconciliation of stamps held
- stamps applied, and stamped stock on hand by stock keeping unit and batch
- identification of stamped items released for consumption against those exported or destroyed
Movement under duty suspension
You must keep documents evidencing entry to or dispatch from approved premises and, where applicable, Excise Movement Control System (EMCS) administrative references for Northern Ireland to EU movements.
Imports
You must keep a record of:
- customs declaration data, commodity codes, values and quantities
- evidence of excise treatment at import (release for consumption or immediate entry to duty suspension)
- postponed VAT accounting statements (where used), kept separate from the Vaping Products Duty account
Exports, drawback and destruction
You must keep a record of:
- export declarations and proof of exit
- commercial transport documents
- notices and claims (forms EX75 or EX76) and certified destruction records where relevant
- linkage to the original duty payment and stamp records
Returns and adjustments
You must keep a record of:
- workings for monthly return calculations
- corrections
- over‑declarations and claims
- credit control for stamp returns where applicable
Incidents and variances
You must keep a record of:
- reports of shortages or overages
- product or packaging defects affecting volume or stamping
- equipment failures affecting activation or scanning
- the investigation outcome
Systems access and controls
You must keep a record of:
- lists of users authorised to activate or scan stamps
- role-based access controls
- change logs for master data (products or stock keeping units, pack sizes, premises)
Role‑based expectations
The records you must keep may depend on what you do. If more than one role applies to you, you must keep all of the relevant records for each role.
Manufacturers
If you manufacture vaping products in the UK, you must keep records that show what you produced, how much you produced, and how stamps and stock were controlled. These include:
- maintaining production, fill and packaging records showing batch numbers, recipes, volumes, and waste or spoilage
- keeping stamp activation or application logs by line, shift or operator
- reconciling stamps to output and to stamped inventory
- separating stock by duty status (duty‑suspended or duty‑paid) and by stamping status (unstamped, stamped, exported or destroyed)
Importers
If you import vaping products into the UK, you must keep records that show how the goods were declared, whether duty was paid or suspended, and how any stamps were applied. These include:
- retaining import declarations, invoices and packing lists
- evidence of whether goods entered duty suspension or were released for consumption
- where products are released for consumption on import, ensure stamps were affixed in time and keep evidence of stamp activation or application linked to the import entry
- keeping postponed VAT accounting evidence separate from the Vaping Products Duty records and ensure quantities and volumes match across systems
Warehousekeepers
If you are an excise or customs warehousekeeper, you must keep records that show what vaping products were received, stored, moved and released, and whether duty suspension rules were followed. These include:
- keeping warehouse stock accounts (by owner, product and duty status), receipts or dispatches, and references for movements in duty suspension (including EMCS where applicable)
- if affixing stamps in warehouse, keep activation or application and scanning records, and ensure duty‑suspended restrictions for stamped stock are followed
UK representatives
If you act as a UK representative for an overseas manufacturer, you must keep records that show your approvals, stamp orders, guarantees and how stamps were controlled. These include:
- keeping approvals, guarantees and due diligence over counterparties
- stamp orders or shipments to named overseas affixers
- reconciliation of stamps ordered, dispatched, applied and returned
- incident logs (loss, theft or damage)
- retaining the data exported from the supplier platform for audit, including who applied or activated stamps overseas and when
Wholesalers and retailers
If you sell or handle duty-paid vaping products for wholesale or retail, you must keep records that show where the products came from, what you sold, and what checks you made to make sure products were legitimate. These include:
- maintaining purchasing and sales records showing supplier, date, stock keeping unit, volume and stamp presence on retail packs
- keeping due‑diligence checks on suppliers and evidence that products offered for sale are legitimately stamped after 1 April 2027
- recording any seizures or suspected counterfeit or faulty stamps and actions taken
Format of records and system requirements
You can keep records on paper or electronically, but they must be complete, readable and available to HMRC when asked. In particular for:
- keeping records on paper or electronically, electronic records must be backed up and exportable on request in a readable format
- where you use your own documents instead of official forms, they must contain all the information that HMRC requires and be uniquely identifiable
All records must be kept in English (or be readily convertible into English) and be available for inspection at the place of business or another agreed location.
Reconciliations and periodic controls you should operate
You should carry out regular checks to make sure your duty records, stock records and stamp records are accurate and match each other. These should include:
- monthly reconciliation of your duty account to production, movements, imports and sales or dispatches, with explanations for variances
- stamp reconciliation each accounting period
- stamps purchased, received, held, applied, destroyed or returned, and unaccounted for (with incident references)
- inventory counts (at least quarterly) for duty‑suspended and duty‑paid stock, including stamped stock
- investigating and documenting any differences
- data quality checks on stamp scans (missing scans, duplicates, mismatches to product or batch)
Evidence checklist
You should be able to produce evidence that supports your records, duty calculations and use of vaping duty stamps. This may include:
- production or batch sheets
- calibration certificates
- tank or filler dip charts or metering system outputs
- reconciliation of label claims to measured volumes
- stamp orders, delivery notes, storage logs
- activation or application logs
- scanning exports from the supplier platform
- returns or credits
- incident reports
- warehouse accounts and movement documents (including the EMCS electronic administrative document or Administrative Reference Code where relevant)
- delivery or receipt notes and transport documents
- customs declarations (import and export), commercial invoices and packing lists
- postponed VAT accounting statements
- proof of export or certified destruction
- monthly returns, workings and payments adjustment and repayment requests with supporting calculations
- due‑diligence records on suppliers or customers
- staff training and authorisation lists for stamping and scanning operations
Providing records to HMRC
You must make records available to HMRC officers on request. Where records are electronic, provide a readable export together with any explanations needed to understand codes and data fields.