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HMRC internal manual

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

Specification Letter



Specification letter


Specification of Tobacco Products

The Tobacco Products Duty Act 1979 section 7A(4), allows us to specify the following brands of product, produced by [insert name of trader] companies and marketed in the countries listed. The specified brands are brands of tobacco that have been identified, from historical data on seizures, as being a substantial source of smuggled tobacco product into the UK.









  • [insert brand names]





  • [insert countries]



  • [Insert names]

Further information required

Under the Tobacco Products Duty Act 1979, section 7A( 5), due to the significant risk associated with the specified brand, countries and persons as detailed above, you will be required to provide us with more detailed information about them. Details of the information we require are provided below.

You should also review your policy for avoiding facilitating smuggling in connection with these and consider any reasonably practicable steps to improve your controls.

[insert specified country] Domestic Market






  1. An overview for the structure of the [insert name of trader] products marketing channels in [insert specified country].
  2. The total number of customers supplied with both specified products, split between those known to be wholesalers and those known to be retailers.
  3. Details of the total volumes supplied to all customers in [insert specified country] over the last five years, expressed as a total for each year.
  4. The names and addresses of the top five customers in [insert specified country], including the address of their principal place of business and the addresses where supplies are delivered.
  5. The name of the person within the named individual companies who is responsible for placing the orders for the [insert specified country] product.
  6. A copy of the documents your company use to make the various credibility and security checks in relation to the top five customers in [insert specified country].
  7. Details of volumes, on an individual company basis, of the specified products supplied to the top five businesses over the last five years, expressed as annual totals for each year.
  8. Notification of any changes that you intend to make to your supply chain policy in regard to the supplies of the specified product in the specified market




In relation to the information requested you have a period of 21 working days from the date of this letter to provide me with the details, however if there is a particular problem with this timescale I will be happy to discuss reasonable alternatives with you.

Period of Specification

It is also our intention to monitor the indicators of smuggling of the specified product from the specified markets over the next twelve months. At the end of that period we will carry out further evaluation before deciding whether to extend the period of this specification. If the risk has significantly diminished we will remove the designation and inform you of this in writing.

Yours sincerely