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25th May 2012

BBPA issues ‘Ten Point Plan’ to tackle duty fraud

The British Beer & Pub Association has issued a ten point plan to tackle beer duty fraud to complement and build on the current alcohol fraud strategy, which it says, eliminates any need for costly beer stamps or supply chain legislation – new ‘red tape’ for the brewing industry that is currently being considered by the Government.

The BBPA is committed to tackling duty fraud – but does not believe the problem is anywhere near the scale suggested by HMRC – and that ‘tax stamps’ or ‘fiscal marks’ for every can and bottle of beer are a totally disproportionate response that ultimately would not stop fraud.

Measures being put forward by the BBPA have been shared with the All Party Parliamentary Beer Group, which is currently conducting an inquiry amidst growing concerns over the issue.

The BBPA’s ten proposals involve collecting and sharing more robust data on beer movements and trading patterns, and implementing rigorous ‘know-your-customer’ programmes. In turn, working closely with the industry, HMRC should beef up its own monitoring and enforcement measures, the association says.

The ten points in full are as follows:


  1. BBPA to collate duty-in-suspense sales from brewers by trade channel to assist in (a) monitoring the volume and trends in this market and (b) produce a robust upper and lower bound estimate of beer fraud.
  2. Individual brewers to continue to supply HMRC with a regular detailed breakdown of sales to customers in duty-to-suspense to both UK and EU, including volumes.
  3. Brewers to continue to review due diligence processes and implement rigorous know-your-customer programmes. BBPA to develop minimum recommended requirements consummate with size and risk.
  4. Brewers to provide timely information and intelligence on suspicious trading patterns and from due diligence actions
  5. Brewers to investigate cost-effective technologies and how voluntary UK-specific labelling  could enhance tracking capabilities  and respond in a timely manner to track-and-trace requests from HMRC
  6. HMRC to provide a dedicated point of contact for brewers to feed-in intelligence on suspected fraudsters
  7. HMRC to seek similar commitments on traceability, provision of customer information, intelligence  sharing and due-diligence programmes from wholesalers and other beer and wine supply chain agents
  8. HMRC to pursue enhancements to EMCS (Excise Management & Control System, an EU-wide system where any movements of duty-suspended beer are recorded on a central database) to help assist in identifying fraud and fraudsters.*
  9. HMRC and UKBA to actively pursue ways of  improving the monitoring and tracking of consignments of alcohol entering UK ports and act accordingly to start re-balancing the risk and reward away from those involved in alcohol smuggling.**
  10. A joint anti-fraud task force is set-up to monitor and evaluate progress against actions, share insights and consider any additional proposals.


The BBPA is also supportive of the proposal put forward by the Federation of Wholesale Distributors of a registration scheme for alcohol wholesalers which are the one link of the alcohol supply chain that are currently not required to have a licence to sell alcohol.


BBPA Chief Executive Brigid Simmonds comments:


“These common sense proposals are the right way forward. They reflect the fact that HMRC already has the powers to tackle fraud – and we can get results by working more closely together. The current strategy is still to be fully implemented and we certainly don’t need costly new legislation or beer stamps, which would be a huge new burden on our industry at a time when the Government says it wants to cut red tape.”


For further information please contact:

David Wilson, Director of Public Affairs: 020 7627 9151 /

Neil Williams, Communications Manager Tel: (020) 7627 9156 / 07974 249 779

Gareth Barrett, Public Affairs Officer Tel: (020) 7627 9154


Notes to editors:


*EMCS currently provides almost no intelligence to HMRC as it can only look at single movements. This should be an essential anti-fraud tool in looking at unusual patterns/trends, journey times, etc. Currently there is no requirement to include the owner of goods being moved which would seem a crucial piece of information.


**This should include pre-notification and recording of Administrative Reference Codes (ARCs), investigating separate lanes at ports, technologies for bulk scanning, regular and higher profile searches, visual warnings and publicity of tough actions taken against smugglers.


The British Beer & Pub Association is the UK’s leading organisation representing the brewing and pub sector.  Its members account for 96 per cent of the beer brewed in the UK and around half of Britain’s 51,000 pubs.




Neil Williams

Communications Manager

British Beer & Pub Association

020 7627 9156

07974 249 779