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HMRC internal manual

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

Controls for avoiding facilitating smuggling- principles: Assurance of policies for avoiding facilitating smuggling


It is a primary responsibility of LB, as part of their assurance programme, to ensure that tobacco manufactures have policies for avoiding facilitating smuggling and assure whether they comply with them. In particular, LB should consider how the controls specified in their policies to avoid facilitating smuggling have been applied in relation to any notified seizures (see section TOBCSC5000). Where a tobacco manufacturer does not have a policy or is not complying with the terms of his stated policy, and they are unable to achieve a satisfactory solution with the tobacco manufacturer, the extent of that non-compliance will help inform any subsequent decision to issue an initial notice, and in the event of a penalty notice, the size of any penalty.