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HMRC internal manual

Tobacco Products Duty

Electronic Removal: Requests to operate 'electronic removal'

A trader may request “electronic removal” when applying:

  1. to register a new store; or
  2. to convert an existing conventional (“physical removal”) registered store to electronic removal.

In both instances the trader will be required to meet the conditions listed at section TPD10040 below before you grant approval for “electronic removal”.

A manufacturer may apply to register both “conventional” and “electronic removal” Regulation 8(4), of the “Tobacco Products Regulations 2001”, requires occupiers of registered stores to give reasonable notice of their intention to repack tobacco products. This requirement is restated in section 6.7 of Notice 476, where ‘reasonable notice’ is taken to be a period of at least 24 hours excluding weekends and public holidays. You may agree standing arrangements if the manufacturer wishes to carry out regular or continuous re-packing.

Operations other than repacking should not normally be necessary but may occur in exceptional circumstances (e.g. for preservation following fire, water damage, etc). The replacement of samples drawn from stock for Department of Health tests or for short-packed or damaged cases can also occur. Any repacking in the registered store should be authorised by the trader’s management, the type of operation noted and the date and stock references recorded.

Manufacturers who have opted to “break bulk” within the registered store, may repack retail packs of products provided no disturbance of their contents is involved.

Where a manufacturer has opted not to ‘break bulk’ in the registered store, repacking should be limited to the replacement of stock taken for Department of Health sampling. Any further interference with stock units would endanger the offsetting arrangements.

The same premises cannot be registered as both “conventional” and “electronic removal” stores. The mixed storage of duty-paid and duty-suspended tobacco products can only be allowed in registered stores approved for “electronic removal”. The approval letter must indicate whether or not the premises are approved for “electronic removal” and list the conditions pertaining to that approval.