Supply Chain Controls - principles: Content of a supply chain policy
The content of a supply chain policy is not prescribed by HMRC as tobacco manufacturers are best placed to design their policies around their particular circumstances. Tobacco manufacturers should regularly review the content of their policies to ensure they remain flexible and responsive to any developments in smuggling risks.
The key is that policies are tailored to the risks of particular circumstances and are not generic.
Appendix A to Notice 477 offers suggestions for the sort of thing that may form part of a supply chain policy. The appendix is a good starting point not just for tobacco manufacturers, but also for any officer who needs to evaluate a tobacco manufacturer’s policy. The controls suggested in the notice are not mandatory, nor exhaustive, and tobacco manufacturers should be encouraged to develop their policies to address any risks in their particular supply chains.
Up to date copies of supply chain policies for the major UK tobacco manufacturers must be retained by LBS and TCoE and, where necessary, copied to other interested business areas.