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HMRC internal manual

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

Initial Notices: What is an initial notice?



An initial notice is a written warning to a tobacco manufacturer where HMRC believe that they may be failing in their duty not to facilitate smuggling, and as a result they may be liable to a penalty. It includes the following information:



  • an explanation of why the notice has been issued. This should take into consideration previous written advice and concerns and the results of any supply chain audits undertaken;
  • an explanation of how the factors that must be taken into consideration (set out in paragraph TOBCSC7100 below) have been applied;
  • the effective dates for the notice;
  • an explanation of why we do not think that there is a reasonable excuse for what appears to be non-compliance;
  • a warning regarding the possible imposition of a penalty;
  • notification that the tobacco manufacturer is being given the opportunity to address the concerns set out in the Initial notice and therefore to avoid a penalty;
  • contact details for the tobacco manufacturer to discuss the initial notice with us.

LB TCSM is responsible for deciding whether an initial notice should be issued and will be informed by discussion with Tobacco Policy.