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HMRC internal manual

Excise Due Diligence Condition guidance

The due diligence condition: a high level view of the condition

The excise due diligence condition, which has force of law, is a registration condition for those businesses listed in EDDC01010. It is brought into effect by its inclusion in the following notices:

Notice 226: Beer Duty (GOV.UK)

Notice 203a: Registered Consignees (GOV.UK)

Notice 204a: Temporary Registered Consignees (GOV.UK)

Notice 204b: Commercial Importers and Tax Representatives - EU trade in duty-paid excise goods (GOV.UK) 

Notice 196: Excise Goods- registration and approval of warehousekeepers, warehouse premises, owners of goods and registered consignors (GOV.UK)

Notice 2002: Alcohol Wholesaler Registration Scheme (GOV.UK)

The condition in each notice requires that a business must:

  1. objectively assess the risks of alcohol duty fraud within the supply chains in which it operates
  2. put in place reasonable and proportionate checks, in its day to day trading, to identify transactions that may lead to fraud or involve goods on which duty may have been evaded
  3. have procedures in place to take timely and effective mitigating action where a risk of fraud is identified
  4. document the checks it intends to carry out and have appropriate management governance in place to ensure that these are, and continue to be, carried out as intended


All approved businesses are expected to take appropriate steps to reduce the risk of alcohol fraud in their supply chains and transactions. Each notice provides guidance to help businesses assess risks.