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HMRC internal manual

Holding and Movements Assurance Guidance

Excise Movement and Control System: assurance checks: fallback procedures

The table below lists basic checks that could be made to help counteract the risks associated with not following the fallback procedures fully and correctly.

The different columns cover the different scenarios where fallback procedures may have been used:

  • the ‘Goods dispatched’ column lists the checks that could be made to ensure that a trader has dispatched goods following the fallback procedure correctly and appropriately
  • the ‘CoD’ column lists the checks that could be made to ensure that a trader has changed the destination of goods following the fallback procedure correctly and appropriately
  • the ‘Splitting’ column lists the checks that could be made to ensure that a trader has split a consignment of energy products following the fallback procedures correctly and appropriately
  • the ‘Goods received with FAD’ column lists the checks that could be made to ensure that a trader followed the correct procedure on receipt of a movement with a FAD rather than an ARC
  • the ‘RoR delayed’ column lists the checks that could be made to ensure that a trader followed the correct procedure where EMCS was not available to submit a RoR.
Basic fallback checks Goods dispatched CoD Splitting Goods received with FAD RoR delayed  
             
Ask the trader why fallback procedures were used to ensure it was for genuine reasons (ie EMCS was not available due to a genuine IT system problem). Look at historic data - will the trader remember why fallback was used - what if they haven’t kept a record? X X X   X  
Check relevant Fallback document was completed correctly (the trader must keep a copy) X X X      
Check the Notification of Movement starting in Fallback template was completed correctly and it matches the details in the FAD, including the LRN (NSD can confirm the details on the notification received). X          
Check the relevant Fallback document was correctly emailed (or exceptionally faxed) to the NSD before the movement began / the destination was changed / the split occurred (the NSD can confirm the date and time the notification was received). X X X      
If goods were received with a FAD, check the movement was entered into EMCS and that, the details on EMCS and the FAD match. If not, verify to ensure the consignor’s control officer is aware, particularly if in another MS.       X    
Check the electronic message was submitted retrospectively on EMCS as soon as possible after the system problem was resolved. X X X   X  
Check the electronic message was submitted retrospectively on EMCS as soon as possible after the system problem was resolved. X          
Check the correct start date and time of the movement were entered when the movement was submitted on EMCS (ensure a false / later start date or start time was not used). X          
Check the details submitted on EMCS exactly match the details in the Fallback document. Note: check the LRN matches. X X X      
If the movement originally started in fallback, ensure that the FAD was captured on EMCS, first followed by the Fallback CoD and / or Fallback Splitting Operation document.   X X      
Check the electronic RoR was submitted on EMCS (a paper Fallback RoR from another MS does not discharge the movement. The movement is discharged when the RoR is successfully submitted on EMCS, depending on the interval between the check and the movement. X X X X X