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HMRC internal manual

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

Supply Chain Controls - principles: Dialogue with tobacco manufacturers about supply chain policies


We should be pro-active in seeking to discuss supply chain policies with tobacco manufacturers, as both parties can benefit from a combined understanding of supply chain issues. We do not, however, approve or agree policies as this may compromise any subsequent action that we may wish to take in respect of a manufacturer’s failure to comply with his duty not to facilitate smuggling.

Where a tobacco manufacturer wishes to discuss their supply chain policy this will, in the first instance, be the responsibility of LBS. They will be supported in any discussion by TCoE, who will be able to provide technical advice on any measures in the policy; and by ESM regarding the legal context and interpretation of law, policy and guidance.