Alcohol & tobacco
Restricted Goods

As distributors of tobacco products, FWD members help to ensure that age-restricted goods are sold legally through responsible retailers.

We are currently concerned about the implementation of tobacco tracking trace legislation, which was introduced in 2019 and is now subject to revision as the UK prepares to exit the EU.



Since the introduction of the highly successful Alcohol Wholesaler Registration Scheme (AWRS) in April 2017 (pushed for by FWD) we’ve seen a marked decline in the illicit trade in alcohol. However, there is still more work to be done on enforcement of this scheme and it is essential that the Government continues to be vigilant in tackling fraud and illegal traders.

Further, following the introduction of the Soft Drinks Industry Levy in April 2018, we are now concerned about the rise of a soft drinks grey market. It appears to be the case that unscrupulous importers are bringing stock into the UK that has not been subject to the levy.

Tobacco and alcohol
Responsible distribution

 Tobacco Track and Trace

HMRC has responded to our questions regarding outstanding issues with the track and trace system, which is attached to this update. Please let us know if the responses to the questions are able to resolve the issues you are experiencing in your business or if more clarification or detail is needed. The questions do not provide too much extra detail to what is already known, although there is some clarity about technical areas regarding despatch.

If you require further clarification or information, HMRC has asked if specific examples could be provided of the issues or operational difficulties that your business is facing so that they can provide a more detailed response.

Reporting product movements

The EU Commission has published a document of common reporting mistakes found since the EU Secondary Repository and Router have been in operation. Also published is the EU System of Tobacco Traceability information sheet, which outlines the rules for the reporting of product movement within the distribution chain.

The documents can be found here:

Tobacco for heating

HMRC’s IT systems and forms have been updated for the recording of tobacco for heating (TfH). From 1 November 2019, traders are required to use the updated systems and forms to declare excise duty for any TfH products under Tax Type code 633. This process will replace previous instructions of recording TfH as hand-rolling tobacco.

Since November 2019, all TfH products must be recorded on forms and systems, as follows: TP7 (43633), W6 (31633) and W6D (633).

In addition, it will no longer be necessary to maintain additional records when using the updated IT sys- tems. Traders must however, retain any previous records that were used to verify the proportion of TfH recorded under the hand-rolling tobacco tax type of 619.