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HMRC internal manual

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

Penalty notices: Factor 5 - What action has the manufacturer taken to in response to specified brands and countries? Maximum score 5 points.


Specified brands, countries and or persons are covered in section TOBCSC4000 of this guidance.

This factor addresses any additional steps the manufacturer has taken in respect of specified brands, countries and or persons over and above those standard practices contained in their policy for avoiding facilitating smuggling. Where all reasonable controls are already in place, or a manufacturer takes positive action to ensure that they are implemented in the future, HMRC should allocate a nil score. Where they fail to respond to the additional risks HMRC should allocate a score up to 5 points.