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HMRC internal manual

Excise Due Diligence Condition guidance

General: which businesses are captured by the due diligence condition?

Due diligence, in relation to alcohol duty fraud, became a condition of approval on 1 November 2014 for breweries approved to trade in duty suspension under section 41A of the Alcoholic Liquor Duties Act 1979 and on the following approvals registered under section 100G of the Customs and Excise Management Act 1979:

  • Authorised Excise Warehousekeepers
  • Registered Owners of Goods (within an excise warehouse)
  • Registered Tax Representatives
  • Registered Commercial Importers
  • Temporary Registered Consignees
  • Registered Consignees
  • Registered Consignors


Due diligence also became a condition of approval on 1 January 2016 for businesses approved under ALDA 1979 part 6A section 88c as wholesalers of alcohol under the Alcohol Wholesaler Registration Scheme (AWRS)

It is aimed at those who are dealing in alcoholic liquor goods.