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HMRC internal manual

Tobacco: Anti-smuggling or the duty to avoid facilitating smuggling

Controls for avoiding facilitating smuggling - principles: Content of a policy for avoiding facilitating smuggling


The content of a policy to avoid facilitating smuggling 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 that 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.

Notice 477 offers suggestions for the sort of thing that may form part of a written policy. The notice 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, but provide examples of the measures and controls that HMRC would expect to see when assessing whether reasonable actions have been taken. Tobacco manufacturers should be encouraged to develop their policies to address any risks in their particular supply chains.

Up to date copies of policies for avoiding facilitating smuggling for the major tobacco manufacturers must be retained by LB and, where necessary, copied to other interested business areas.