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HMRC internal manual

Holding and Movements Assurance Guidance

HM Revenue & Customs
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Excise Movement and Control System: assurance checks: EMCS electronic procedures

The table below lists basic checks that could be made to help counteract the risks associated with the use of the eAD:

  • The ‘Prior to visit’ column lists the checks that should be made before you visit the trader.
  • The ‘Initial checks’ column lists the checks that should be made on the initial visit and confirmed on subsequent visits.
  • The ‘Receipts’ column lists the checks that could be made to ensure that a trader has procedures in place for receiving goods.
  • The ‘Removals’ column lists the checks that could be made to ensure that a trader has procedures in place for removing goods.
Basic checks Prior to visit Initial checks Receipts Removals  
Does the trader use the portal or his own software? Do you need specialist assistance to audit this software   X      
Has the trader trained his staff in accessing EMCS via the portal?   X      
Does the warehousekeeper or registered consignee check his EMCS account on a daily basis for intended arrivals     X    
Are losses or surpluses actually recorded on EMCS?     X    
Is the RoR given in time? X   X    
Does the trader have access to HMRC or his own software guidance on completing the draft eAD?   X   X  
Check procedures are in place to ensure goods are not removed before the ARC is allocated.       X  
Does the trader have procedures to make a CoD in place after the goods have left the warehouse?       X  
What procedures exist to check that the RoR / report of export is received?       X  
How many open movements are there? Investigate why they remain outstanding during the visit. X     X  
Does the trader have manual fallback procedures in place when EMCS is not available?   X   X  
Have all the fields been completed with correct information (for example vehicle registration details)?   X      
Does the trader verify stock received with the exact description on EMCS? Compare stock arrived and available with declaration made.     X    
Are there many instances of CoD procedures being used? X        

Even where a field is mandatory, as a general rule EMCS only validates the data in that field, not the accuracy of the information entered (the exception to this is excise IDs and excise product codes which are validated against SEED, to verify that the consignor and consignee are authorised to deal in duty-suspended products of that specific type). This means that information entered may be inaccurate or misleading, or even be nonsense, as it is possible to enter non-standard characters in most of these fields (for example *,&,$, ! etc). This is why it is important that officers verify the data on any eADs they may view.

For exports and deliveries to exempt organisations a consignee excise ID is not required on the eAD, as the final destination is not an authorised excise trader in the EU. You should pay careful attention to any of these movement types to ensure that the information on the eAD supports the movement type selected. There have been instances where these movement types have been selected either in error or to bypass the requirement for a consignee excise ID. In either case, no validation of the consignee has been carried out by EMCS, therefore it is possible that goods may be delivered to someone not authorised to receive them.

Officers should consider further investigation of movements that were consigned to the trader you are assuring but were subsequently diverted to an alternative destination. There is often a reasonable explanation for a CoD, for example the goods were no longer wanted, or they were incorrect. However, regular occurrences of this nature could highlight a potential problem. In particular, where there is a CoD for an intra-EU movement after the goods should have arrived in the UK, and the new destination is outside the UK, there is potential that the goods will never leave the UK and will be illegally diverted onto the UK market.

Where a UK consignor appears to have regular rejections, refusals and/or CoDs for their consignments, this may highlight a problem. Ensure the trader understands how to use EMCS, and the business has processes in place to ensure that the correct information is entered on the eAD and this matches what is actually sent out. One of the main reasons for a rejection / refusal is that the wrong goods have been sent, or the eAD suggests that the goods are not what were ordered. If the eAD does not match what has physically been sent, then those goods are not covered by the eAD and have been illegally removed from the warehouse.