VPDS145000 - Vaping Products Duty and Vaping Duty Stamps: Duty stamps - approval: Quantity of duty stamps

A trader or overseas trader who wishes to affix duty stamps to vaping products will have an imposed limit of how many stamps they may obtain in a fixed period. A trader or UK representative may make a written request to exceed this number if they need more stamps. Likewise, HMRC may vary the time limit or number of stamps that a trader can acquire. This will be the total number of stamps they are permitted to acquire in a three-month period.

To calculate this, you need to take the following approaches:

  • for an established business, look at the previous 12 months throughput and divide this by 4 (to give a quarterly throughput). 10% can then be added as a contingency
  • for a newly established business, the number of duty stamps needs to be reasonably ascertained from their business plan based on proposed throughput

The trader may exceed the allowance you set by up to 30% each quarter in the case of UK Representatives as “room-to-grow". You should be careful not to provide for this yourself. In the case of a UK Representative, this figure is 50%.

Their limit will automatically grow quarter on quarter where they exceed their allowance. It will not automatically reduce. For example:

Quarter 1:
Allowance: 1000 (+30%)
Used: 1300

Quarter 2:
Allowance: 1690 (+30%)
Used: 1200

Quarter 3:
Allowance: 1690 (+30%)
Used: 1700

Quarter 4:
Allowance 1700 (+30%)
Used 2000

And so on...

HMRC may unilaterally reduce the trader’s limit where it is not being used. You should exercise this discretion carefully.

The supplier’s systems will not allow a trader to place an order beyond their allowance.

In exceptional circumstances – the trader may at any time request to HMRC to vary their limit beyond the 30% uplift. This should come with a clear, time-bound, evidenced business need (e.g. in case of supply shocks, like a Suez Canal incident). You must exercise reasonable judgment on the new limit.

If you are of the opinion that the number of stamps requested is too high and unsupported by the evidence, then you can impose a lower amount, however you should engage with the trader to explain why this is your decision and try to come to an agreement. You should bear in mind that this is a relevant decision and therefore subject to the appeal process should the trader disagree with your conclusion.

For UK Representatives, the number of stamps stated on the approval letter will be for the total amount they are authorised to receive across all the overseas manufacturers that they represent. For example, if they represent 5 overseas manufacturers, each with a throughput of 350,000 per quarter, then the UK duty representative’s approval letter will state they are entitled to 1,750,000 stamps as a whole, per quarter.

Any levels imposed must only be in multiples of 1,000.

It is important to note that stamp purchase limits apply to all approved business, not just overseas ones.