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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 and countries are covered in part 4 of this guidance.

This factor addresses any additional steps the manufacturer has taken in respect of specified brands and countries, over and above those standard practices contained in his supply chain policy. Where all reasonable controls are already in place, or a manufacturer takes positive action to ensure that they are implemented in the future, we should allocate a nil score. Where he fails to respond to the additional risks we should allocate a score up to 5 points.