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HMRC internal manual

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

Initial Notices: What happens at the end of the initial period?



Following the six-month initial notice period, the LB Tobacco Anti Smuggling Compliance Manager must collate and evaluate all the information and make a report recommending that either a penalty is issued, or not. In doing this they will be supported by Tobacco Policy.

The report must include the following:


  • any available evidence relating to the perceived failure;
  • what, if anything, the tobacco manufacturer has done about it;
  • a schedule of all notified seizures made during the six-month initial notice period;
  • an analysis relating to the nine factors that must be considered in determining the penalty value (section TOBCSC8000); and
  • a recommendation as to what action should be taken.