Technical guidance: What are the distillers' responsibilities under this regime?
We expect distillers to exercise care and control over all aspects of their revenue activities including:
- the physical security of their premises, plant, vessels and so on. As well as securing and controlling access to the production buildings, the actual vessels where the spirits are produced and stored must also be subject to security measures. By merely securing the buildings and nominating plant operators as keyholders does not discharge the distiller’s responsibilities. Regulation 4(4)of TSR allows us to vary or add conditions to the approval of any plant or process. This includes the condition of security;
- the security of spirits produced;
- the maintenance of accurate records and accounts;
- the accurate taking and recording of accounts;
- the timely rendering of returns;
- the examination of losses and establishment of their cause;
- the investigation of any irregularity at their premises; and
- the implementation and monitoring of reasonable and effective measures to prevent any loss of dutiable spirits.
We expect them to demonstrate that they are discharging those responsibilities, for example by means of adequate management systems and controls.