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HMRC internal manual

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

Penalty notices:Factor 2 - What action has the manufacturer taken to ensure they have complied with their legal duty? Maximum score 10 points.


The supply chain control regime is designed to give manufacturers every opportunity to comply with their duty and HMRC will share information with the manufacturer and comment on the effectiveness of their controls. Where, in our opinion, the manufacturer could reasonably have done more to comply with his legal duty, they should be scored as follows:

Some action, but not comprehensive score up to 5
Little or no action score up to 10