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HMRC internal manual

Tobacco Products Duty

Registration: Policy on storage of non-excisable (innocent) goods

A manufacturer wishing to store non-excisable goods (i.e. goods not subject to excise duty) in a registered store should make written application to the National Registration Unit. The application should be made either as part of a request for registration or as a request to vary an existing registration.

Before approving any request for the storage of “innocent” goods, you should consider the following points.

  • Stores are registered for the safe storage of tobacco products without payment of duty. (See s.7(b) of the Tobacco Products Duty Act 1979 and regulation 5 of the Tobacco Products Regulations 2001). It follows that, wherever possible, the trader should request the de-registration of premises or part premises, which are used for the storage of tobacco products. (“Part premises” refers to the securely bounded part of larger premises – see section TPD3110.)
  • Where such de-registration is not practicable, the trader may request a variation to the registration of the store concerned, to allow the storage of “innocent” goods therein.
  • You should include any particular conditions, relating to the storage of “innocent” goods, in the registration letter.
  • “Innocent” goods must be physically segregated within the store, unless the store is approved for “electronic” removal and the electronic stock control/movement records are capable of recording and tracking the movement of “innocent” goods into, within and out of the store concerned.
  • Any customs duty or import/acquisition VAT due on the “innocent” goods must be paid or accounted for before the goods enter the registered store.
  • Any request to store other excise goods (e.g. beer or wine) in a registered store must be refused.
  • Any request to store “innocent” goods in a registered factory must be refused.