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HMRC internal manual

Duty Free Spirits Guidance

Technical Guidance: Can an unauthorised person order Duty Free Spirits on behalf of an authorised person?

It is possible for “Dry brokers” or “Dry suppliers”, who hold no stocks, to order DFS on behalf of an authorised trader. However, the order from the customer must include an original statement of authority to receive DFS. This is likely to occur when the customer gets all his chemicals from a single source but the supplier is not a warehouse that can supply DFS. The supplier, although not authorised to receive DFS, can pass the order on to another as long as the original authority to receive statement is passed on as well. This chain of “Dry Suppliers” may be of any length providing each passes on the original statement of authority.

The final supplier, ie the warehouse, can only send the DFS direct to the authorised customer but the paperwork goes back down the chain of dry suppliers. Thus, no unauthorised person receives DFS which passes direct from warehouse to user.