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HMRC internal manual

Customs Civil Penalties Guidance

HM Revenue & Customs
, see all updates


Term Meaning
Authorisation An agreement from HMRC which allows a trader to operate a Customs facility or to use a particular regime.
Authorised trader A trader who has an authorisation from HMRC to perform a task etc.
Broadly similar contravention A contravention that breaches similar provisions to that covered by the original warning letter.
CITEX Customs and International Trade and Excise
Civil penalty Penalty for a contravention of Customs law that is not a criminal sanction.
Contravention A breach of Customs law.
Customs Penalty Action Checklist (CPAC) The form used as the decision making tool for all CCP action.
Deficiencies in systems, records, security of premises etc Type of contravention involving these subjects.
Direct agent Agent who acts in the name of and on behalf of the trader.
Direct penalty / direct to penalty We charge a penalty without first issuing a warning letter.
Education Help that we can provide to a trader to improve their understanding of what is required of them.
Failure to produce records or information Type of contravention involving these subjects.
Indirect agent Agent who acts in their own name but on behalf of another person.
Mitigation Reduction of the amount of a civil penalty
Penalty notice Notice that charges a civil penalty on a trader or agent.
Poor compliance Type of contravention including failures, inaccuracies, inappropriate use etc. but not serious errors.
Reasonable excuse An excuse for making the contravention which is reasonable when all the facts of the situation are considered.
Serious error Type of contravention involving errors potentially resulting in non-payment of significant amounts of Customs duty and import VAT or where the contravention has a detrimental effect on the physical control of the goods.
Unauthorised trader A trader who does not have an authorisation from HMRC to perform a task etc.
Warning letter Letter that warns the trader or agent that if there is a further broadly similar contravention within a set period we may charge a penalty without further notice.