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HMRC internal manual

Holding and Movements Assurance Guidance

Excise Movement and Control System: information available to assist in auditing a duty-suspended movement: fallback movement information available from the National Service Desk (NSD)

Before carrying out an audit visit, an officer can ask the NSD for information regarding movements that have taken place using fallback procedures.

Before a UK trader uses fallback procedures to dispatch a movement, change the destination of a movement, or split a movement of energy products they must email or fax a notification to the NSD. The NSD keep a record of all the data items contained in the notifications including the date and time they were received. The NSD also keep a record of all the periods when EMCS was not available in the UK or in another MS. Traders using fallback do not need to be granted permission to do so, as this could hinder trade if the request came through when the NSD is closed. However, use of fallback should be challenged where the procedure is not being followed correctly or it is being used in inappropriate circumstances.

Data items recorded by the NSD include all information required on the relevant fallback document.

Note: There is no indication given to the NSD by any trader as to why fallback is being used, although Notice 197 (HMRC website) mentions that it is in their interest to keep sufficient evidence to show why EMCS was not available.

Examples of the information that can be requested from the NSD include:

  • whether a trader used fallback procedures in a specific period to dispatch goods or change the destination of a movement. This can include full details of the information submitted on the notification plus the date and time the notification was received
  • for intra-UK movements only, whether a trader received goods from a UK consignor, in fallback, between specific dates
  • whether there were periods between specified dates when EMCS as a whole was not available in either the UK or in another MS.

Requests to the NSD for fallback information should be made by email to the(This content has been withheld because of exemptions in the Freedom of Information Act 2000) EMCS.Helpdesk, Harwich, stating exactly what information is required including, as appropriate, the consignor Excise ID, the warehouse Excise ID, and the dates from for which the information is required.

In essential circumstances, and for short periods of time, an officer may also ask the NSD to inform them in ‘real time’ if a particular trader notifies HMRC that they are about to use fallback procedures. This may be appropriate if, for example, an officer is monitoring movements from a warehouse for a specified short term period.

The NSD will also inform officers if a trader submits incomplete or incorrectly completed fallback notifications, or if they notice that a trader appears to be using fallback more than would seem usual. (The NSD will send information to LBS if it is a large business trader or Local Compliance if it is not. The NSD have up to date contact lists for both areas.)