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HMRC internal manual

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

Controls for avoiding facilitating smuggling - principles: Dialogue with tobacco manufacturers about policies for avoiding facilitating smuggling


We should be pro-active in seeking to discuss policies to avoid facilitating smuggling 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 written policy this will, in the first instance, be the responsibility of the Large Business Tobacco Anti-Smuggling Compliance Manager (LB TASCM). They will be able to provide technical advice on any measures in the policy; and Tobacco Policy can provide advice regarding the legal context and interpretation of law, policy and guidance.