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HMRC internal manual

Excise Due Diligence Condition guidance

Compliance visit: risks: existence/provenance of goods

  • the goods are said to be duty paid but the registered person’s supplier cannot provide reasonable evidence of duty payment to support the goods’ status (For further detail on what constitutes evidence of duty payment, see Drawback Notice 207 
  • individuals in the company that the registered trader intends dealing with have little knowledge of their trade sector
  • where a sample is provided or where the business has received the goods:


  • there is no duty stamp (alcoholic spirits) or the duty stamp does not fluoresce on goods received
  • the goods have the general appearance of being counterfeit, in that the quality of labels and or packaging is poor when compared to the genuine article
  • the supporting paperwork seems false
  • the goods are significantly older than evidence of duty payment suggests


  • the company they intend doing business with has only been trading for a very short period of time and yet that company has managed to achieve a large income in that short period of time