Introduction
1. Tobacco smuggling is a significant threat to UK
tax revenues and to public health, yet duty is evaded on nearly
one cigarette in ten, and more than a third of all hand-rolling
tobacco. This is costing the taxpayer nearly £2 billion per
year.[1]
2. There are three illicit product categories. First,
'contraband' are legally manufactured by the major tobacco companies
and smuggled into the UK either from other countries, where they
are duty paid in that country, but due to higher UK duty are still
worth smuggling into the UK. A typical example of contraband in
the UK is French cigarettes in French packs.[2]
3. Second, 'illicit whites' are brands that are legally
manufactured by companies, often based in emerging economies,
with the intent on exporting illegally to other countries through
a smuggling network. The products are then sold illegally without
domestic duty being paid.[3]
Illicit white brands are typically imitation brands that copy
the 'look and feel' of well-known legal brands.[4]
The most common brand is "Jin Ling", which is produced
in Russia, Ukraine and Moldova, although the provenance of many
illicit whites is obscure.[5]
4. Third, 'counterfeit' are illegally manufactured
copies of well-known existing brands. Although they are often
very high quality copies of the pack, they are distinguishable
from legal duty free through the lack of identifiable production
or security markings, and product quality is often poor.[6]
5. The nature of the threat from tobacco smuggling
has evolved since 2000. Then, most large cigarette seizures consisted
of genuine UK brands being smuggled from EU countries with lower
rates of duty. In 2007, non-UK cigarette brands and illicit whites
first began to appear, and by 2012-13 most large seizures were
of illicit whites. [7]
6. Tobacco smuggling is associated with organised
crime, including the smuggling of controlled drugs, weapons and
human beings.[8] Along
with counterfeits, HMRC note that illicit whites "represent
the most significant threat to legitimate trade and tobacco revenues
in the UK from large scale organised criminality".[9]
7. Illicit tobacco products have public health implications,
both because they make smoking more affordable and because many
of them are made from unregulated materials. According to the
HMRC, unregulated distribution networks associated with smuggling
make tobacco more accessible to children and young people, and
perpetuate health inequalities between different social groups.[10]
8. Written evidence was submitted by 31 respondents
to the Home Affairs Committee's inquiry into tobacco smuggling.
On 5 November 2013, the Committee took evidence from Paul Williams,
Head of Corporate Affairs UK, Japan Tobacco International, and
Steve Payne, Anti-Illicit Trade, Government Relations & Communications,
Japan Tobacco International. On 11 March 2014, Sir Charles Montgomery,
Director General, Border Force, and Jim Harra, Director General,
Business Tax, HM Revenue & Customs appeared before the Committee.
The strategy to tackle tobacco
smuggling
9. In response to the changing nature of tobacco
smuggling, Tackling Tobacco Smuggling-building on our successes:
A renewed strategy for HM Revenue and Customs and the UK Border
Agency, was published in April 2011. The renewed Strategy
sought "to combine policy and legislative changes, enforcement,
and collaborative working with stakeholders to address the source,
supply and demand for illicit tobacco in the UK".[11]
Within the joint strategy, HMRC has overall responsibility for
delivery, while Border Force is responsible for the seizure of
illicit tobacco at the border.
10. According to the National Audit Office, HMRC's
reported performance against its targets since the introduction
of the new strategy is "mixed", as while HMRC met most
of its objectives in 2011-12, none were met in 2012-13 although
performance improved in most cases from the previous year.[12]
Table 1: HMRC's reported performance against objectives[13]
| | 2011-12
| 2012-13
|
Objective/measure
| | Target
| Achievement |
Target | Achievement
|
Seizures: Seize greater volumes of illicit product to undermine the economics of the fraud
| Cigarettes (millions) |
1,700 | 1,732
| 1,928 | 1,858
|
| Hand-rolling tobacco (tonnes)
| 400 | 572
| 614 | 483
|
Supply: Reduce the availability of genuine tobacco products for fraud
| Cigarettes (millions) |
Less than 1,857 | 1,046
| Less than
1,027
| 1, 042 |
| Hand-rolling tobacco (tonnes)
| Less than 3,306 | 2, 789
| Less than 2,455 | 2,743
|
Criminal investigations: Increase the impact of targeting and disrupting the criminal gangs behind the fraud
|
Revenue loss prevented (millions)
|
No target |
£313
|
£421 |
£378
|
Deterrents: Punish and deter those involved in the fraud
| Assessments and penalties (millions)
| £20 | £8.2
| £30 | £17.7
|
11. Director General, Business Tax, HM Revenue &
Customs Jim Harra stated that it was "right" that they
had "stretching targets" and were "driven by them
to perform even better." He concluded that changes in the
profile of smuggling were making it "increasingly challenging"
for them to make seizures. There has been a move away from use
of the postal channel and the use of large consignments through
containers, as consignments are fragmented into smaller values.[14]
12. In October 2013, HMRC published updated tobacco
'tax gap' estimates. The 'tax gap' is the difference between tax
that is actually collected and the tax that is 'theoretically
due', which is the tax that would be paid if all individuals and
companies complied with both the letter of the law and HMRC's
interpretation of the intention of Parliament in setting law.[15]
13. The mid-point tax-gap estimate shows an increase
in the level of the illicit cigarette market in 2012-13, with
an illicit market share of 9% and associated revenue losses of
£1.1 billion.
Table 2: Cigarettes (Illicit market and revenue
losses)[16]
| 2008-09
| 2009-10 | 2010-11
| 2011--12 | 2012-13
|
Illicit market shares (%)
Upper estimate
Mid-point estimate
Lower estimate
|
15
12
9
|
15
11
8
|
13
9
5
|
12
7
2
|
13
9
4
|
Associated revenue losses (£ million)[17]
Upper estimate
Mid-point estimate
Lower estimate
|
1, 800
1,400
1,000
|
1,800
1,300
900
|
1,500
1,000
500
|
1,500
900
200
|
1,800
1,100
500
|
14. The mid-point estimate of the illicit hand rolling tobacco
market shows an illicit market share of 36%, around the same level
as in 2010-11 and 2011-12. The associated revenue losses for hand
rolling tobacco is estimated to be around £900 million, an
increase compared with previous years explained by the higher
duty rates and prices in 2012-13, together with a slight increase
in the illicit volumes consumed.[18]
Table 3: Hand rolling tobacco (Illicit market
and revenue losses)[19]
| 2008-09
| 2009-10 | 2010-11
| 2011-12 | 2012-13
|
Illicit market shares (%)
Upper estimate
Mid-point estimate
Lower estimate
|
55
50
46
|
48
42
37
|
44
38
32
|
41
35
30
|
42
36
31
|
Associated revenue losses (£ million)[20]
Upper estimate
Mid-point estimate
Lower estimate
|
900
800
700
|
800
700
600
|
800
700
500
|
900
700
600
|
1,100
900
700
|
ARRESTS, PROSECUTIONS AND CONVICTIONS
15. Criminal investigations are a key part of HMRC's approach
to tackling the organised criminal gangs behind large-scale tobacco
smuggling. HMRC has legal powers to seize cash suspected of being
the proceeds of crime and refer cases for prosecution. HMRC targets
the cases that it believes will have the biggest impact, based
on intelligence on organised criminal gangs. The aim is to make
tobacco smuggling into the UK less attractive and factors such
as profit margins, the ease and cost of operating in a country,
the likelihood of being caught and the severity of the sentences
play a key part in determining smuggling routes.[21]
16. Total
spending on the Government's tobacco strategy in 2011-2012 rose
by £3 million to £68.9 million.[22]
This resulted in the seizure of 1.7 billion cigarettes and 572
tonnes of hand-rolling tobacco.[23]
Despite this, in 2012, a total of 1 billion illegal cigarettes
were smoked in the UK, an increase of 49% since 2011.[24]
It is a matter of grave concern that, despite an increase in the
resources devoted to anti-smuggling operations, 49% more illicit
cigarettes managed to slip through the net in 2012 than in 2011,
although this figure stabilised in 2013. In 2012-13, seizure rates
of cigarettes rose slightly to 1.8bn, but the seizure of hand-rolling
tobacco declined to 483 tonnes. The HMRC's tobacco tax gap estimates
rose slightly in 2012-13, to 9 percent for cigarettes and 36 percent
for hand-rolling tobacco.
We are worried that not enough is being done by the Government
and its appropriate agencies to combat the problem of tobacco
smuggling at source. We urge the members of HMRC and Border Force
set up firm relationships with their counterparts in countries
such as Malaysia. This will ensure that intelligence and best
practice is shared.
17. While there have been some high
profile successes,[25]
over the last three years the numbers of prosecutions and convictions
for organised crime cases involving tobacco have fallen. We do
not believe that these numbers are decreasing due to the reduction
in this type of crime and are deeply concerned that these figures
may indicate a reduction in enforcement action.
Table 4: Tobacco arrests and prosecutions[26]
| 2010-11
| 2011-12 | 2012-13
|
Arrests[27]
| 143 | 115
| 156 |
Prosecutions
Organised crime cases
Volume crime cases
Total
|
133 |
62
|
51 |
| 81 |
105 | 214
|
| 214 |
167 | 265
|
Convictions
Organised crime cases
Volume crime cases
Total
|
78 |
52
|
37 |
| 82 |
104 | 122
|
| 100 |
156 | 159
|
18. Civil penalties were also "substantially"
below target in both 2011-12 and 2012-13.[28]
19. John Vine CBE QPM, the Independent Chief Inspector
of Borders and Immigration, scrutinised Border Force freight operations
between March and July 2013. His November 2013 report concluded
that while "Border Force staff employed in freight operations
were committed, knowledgeable and experienced in countering threats
from freight imports", and "Border Force enjoyed a broadly
positive relationship with port authorities", there was a
"breakdown in communication between Border Force and HMRC
at an operational level."[29]
20. A protocol on the referrals from Border Force
to HMRC for criminal investigation has recently been established.[30]
These operating protocols have been updated to articulate referral
and information exchange processes for front-line officers. The
updated guidance has been issued to front-line staff.[31]
A joint debriefing unit has also been established at Dover, focusing
on smuggling on "roll-on, roll-off" ferries.[32]
21. The Committee welcomes recent steps by HMRC and
Border Force to develop more rigorous communication between the
two organisations, in particular, the establishment of a new protocol
on referrals from Border Force to HMRC for criminal investigation.
22. HMRC and Border Force must continue to strengthen
the lines of communication between the two organisations, to ensure
that relevant and up-to-date information is passed between teams.
In particular, it is vital that referrals be made to HMRC in all
cases of seizures where it appears that there might be scope for
sanctions to be imposed. HMRC and Border Force should create a
platform where effective examples of joint-working with local
police forces and partner agencies such as Trading Standards across
the UK can be accessed for training and in order to share good
practice. Without sharing information, raising prosecution and
arrest rates for tobacco smuggling will be more difficult, if
not impossible.
SANCTIONS
23. Tobacco smuggling ranges from individuals abusing
cross-border shopping rules to organised, trans-national criminal
gangs smuggling shipping containers of illicit product around
the globe. HMRC and Border Force state that they have a "comprehensive
and effective range of sanctions available to deter people involved
in all aspects of tobacco fraud and tailored to fit the seriousness
of the offence."[33]
24. HMRC guidance states that tobacco companies are
obliged to keep their supply chain policy under regular review,
and where weaknesses in their supply chain controls are identified,
they should take all reasonable steps to strengthen controls and
include any new measures in their supply chain policy, where necessary.[34]
Tobacco manufacturers face penalties of up to £5m for facilitating
smuggling.[35]
25. Although supplies of UK tobacco products to high-risk
markets have reduced by 20% over the last two years,[36]
HMRC is still concerned about the problem of oversupply of branded
cigarettes overseas with the intention of them being smuggled
back into UK.[37]
HMRC has not, however, fined any UK tobacco manufacturer
for over-supplying products or failing to control its supply-chain,
and has issued only one statutory warning letter threatening a
fine.[38]
26. It is astonishing that no UK tobacco manufacturer
has ever been fined for over-supply of products to high-risk overseas
markets, and that only one statutory warning letter has been issued.
The penalties available are too weak and enforcement too rare.
We find it farcical that a respected enforcement agency such as
HMRC has not imposed tougher punishments on those over-supplying
overseas markets. We recommend that HMRC publish a clear set of
criteria setting out the circumstances in which it would normally
impose a fine and that an immediate review be taken against all
historic and ongoing cases against this criteria in order to ensure
those who have committed an offence do not go unpunished.
27. Sanctions targeted at intermediaries in the illicit
supply chain include: revocation of hauliers' licences and, for
retailers, a fine of up to £5,000, a six-month prohibition
on the sale of tobacco products, removal of any National Lottery
terminal, and revocation of any alcohol licence. HMRC also publishes
details of people or companies deliberately evading duty of more
than £25,000 or convicted of a criminal offence.
28. Large scale smuggling, along with cases of strategic
importance or repeated non-compliance are investigated to a criminal
standard and referred for prosecution. Conviction for the fraudulent
evasion of excise duty carries a maximum sentence of seven years
imprisonment.[39]
29. Other sanctions include civil sanctions, which
are primarily used to tackle small-scale smuggling. Trading Standards
Officers have additional sanctions and penalties for contraventions
of labelling and packaging requirements, age of sale restrictions,
and trademark offences.[40]
30. The Government states that a new communications
strategy is being developed to maximise deterrence.[41]
HMRC indicates that it aims to maximise the use of free media
"to broaden the knowledge and awareness of enforcement action
and penalties, in order to increase its deterrent impact; to raise
awareness and understanding of illicit tobacco products and change
behaviour; to encourage the public and businesses to pass on information
and intelligence on the illicit market."[42]
31. The lack of media reports relating to prosecutions
and enforcement activity in this area is disappointing for two
organisations held in high public regard. As part of their new
communications strategy, HMRC and Border Force should publicise
prosecutions and enforcement action more widely to deter potential
offenders. It is important that the agencies work together to
ensure that those who offend are named and shamed and that the
public money, spent combating this crime, is shown to have been
used effectively.
Mandatory plain packaging
32. Between April and August 2012, the Department
of Health ran a public consultation on the introduction of mandatory
'standardised' packaging for tobacco products.[43]
Some 2,269 detailed responses addressed the question of whether
requiring standardised tobacco packaging would increase the supply
of, or demand for, illicit tobacco or non-duty-paid tobacco in
the United Kingdom, with opinion almost equally divided on the
issue.[44]
33. The summary report on the consultation concluded
that almost all replies from businesses and business-related organisations
suggested that standardised packaging would both increase the
supply of and the demand for illicit tobacco. These respondents
said that standardised packaging would be easier to counterfeit,
reduce counterfeiters' costs and make it easier for counterfeiters
to enter the market. They also believed that standardised packaging
would make it more difficult for law enforcement officers to detect
counterfeit tobacco, especially as members of the public would
be less able to identify when they had been sold counterfeit tobacco.[45]
34. Some consultation respondents considered that
an increase in the size of the illicit tobacco market would be
less of a risk to public health than not introducing standardised
packaging. Some respondents also described how easily and cheaply
counterfeiters could copy current branded packaging and argued
that requiring standardised packaging was largely irrelevant and
would make it neither easier, nor more difficult, for counterfeiters.[46]
35. Written evidence produced during this inquiry
has revealed similar splits in opinion. For instance, the TaxPayers'
Alliance, which describes itself as an "independent grassroots
campaign for lower taxes", argued that that the introduction
of standardised packaging would be "a gift to counterfeiters
and smugglers", citing a 2012 Populus study of 501 serving
police carried out on behalf of the tobacco company Philip Morris
International.[47] When
asked whether the introduction of plain packaging would 'make
it easier to produce/sell counterfeit cigarettes because all packs
will look the same', 86% said that it would, while 68% said that
plain packaging would 'lead to an increase in black market cigarettes
where smuggled branded packs will be available'.[48]
36. Conversely, the Trading Standards Institute (TSI),
a UK national professional association for trading standards professionals
working in the private and public sectors, argues that counterfeiters
are typically able to produce quality counterfeit packaging quickly
and cheaply and that counterfeit tobacco product is detected currently
by the identification of covert markings (on the packaging) using
a hand held scanner, with these and other industry-specific markings
applied to the packaging and product itself. These methods will
continue to be used and thus Trading Standards officers will be
able to detect counterfeit products whether the product is supplied
in standardised packs or not.[49]
37. Nicholas Ilett, an investigation director at
the European Commission (European Anti-Fraud Office), has argued
that "the quality of counterfeits now is so high that it
does not make a great deal of difference whether or not the packs
are plain".[50]
38. In Australia, the Tobacco Plain Packaging Act
2011 and the Trade Mark Amendment (Tobacco Plain Packaging) Act
2011 make it an offence to sell, supply, purchase, package or
manufacture tobacco products or packaging for retail sale that
are not compliant with the plain packaging requirements.[51]
In July 2013, the Secretary of State for Health, Rt Hon
Jeremy Hunt MP, stated that the Government had decided to wait
to make a decision until the emerging impact of the introduction
of standardised packaging in Australia could be measured.[52]
39. In November 2013, the Government commissioned
an independent review of standardised packaging for tobacco by
Sir Cyril Chantler, assessing whether there is likely to be an
effect on public health, particularly for children, if standardised
tobacco packaging were to be introduced. The review was published
in April 2014.
40. Regarding the likely effects on the illicit trade,
Chantler stated that he was "not convinced by the tobacco
industry's argument that standardised packaging would increase
the illicit market, especially in counterfeit cigarettes"
and that there was "no evidence that standardised packaging
is easier to counterfeit." He concluded that the solution
to illicit use was an effective enforcement regime.[53]
41. HMRC have stated that the introduction of standardised
packaging is "not going to create any new risks" for
them, but it could well change the profile of the illicit market.
42. The Committee is encouraged that HMRC is collaborating
with officials in Australia to learn lessons from the introduction
of standardised packaging.[54]
However, it is worth noting that there are significant differences
between the markets in the UK and Australia, particularly in terms
of the proximity to other countries, so the lessons learnt from
the introduction of standardised packaging in Australia may not
necessarily translate to the UK.[55]
43. On 3 April 2014, Parliamentary Under Secretary
of State for Public Health Jane Ellison MP announced that, in
light of the Chantler report and the responses to the previous
consultation in 2012, she was "currently minded to proceed
with introducing regulations to provide for standardised packaging."
Before reaching a final decision, the Government will publish
the draft regulations alongside a final, short consultation.[56]
44. We believe that the decision on standardised
packaging should be driven by health reasons and the imperative
need to reduce the numbers of young people who start smoking.
We note the statement of Sir Cyril Chantler to the effect that
he was not convinced that standardised packaging would bring about
an increase in the illicit market; even if this were the case,
we believe that the proper response would be a more vigorous effort
on enforcement rather than any lessening in the Government's drive
towards introducing standardised packaging.
TRACK AND TRACE TECHNOLOGY
45. A secure track and trace system begins by securely
marking a unit of product, such as a pack of cigarettes, and assigning
to it a unique identity which is stored in a government-owned
and -controlled database. This could provide a fully reliable
test of authenticity and be linked to data, for instance about
product type, time and place of manufacture and intended market
of sale.[57]
46. The unique identity and the database are the
building blocks of a tracking capability which allows the unit
to be followed throughout the supply chainif required,
up to the point of sale to the consumer. They also provide the
means to trace backwards in real-time to point of origin or manufacture
at any time during the product lifecycle.[58]
47. In 2011, the four major tobacco companies, British
American Tobacco, Imperial Tobacco Group PLC, Japan Tobacco International
& Philip Morris International, founded the Digital Coding
and Tracking Association (DCTA) with the stated aim of promoting
cost effective industry standards and supporting technology solutions
to tackle the illicit trade.[59]
Full implementation of the proprietary track and trace technology,
known as 'Codentify', is expected in late 2014 or early 2015.[60]
48. Research in the Journal of Tobacco Control has
raised concerns over the adequacy of Codentify. The authors acknowledged
that they had access to only limited information on Codentify,
through documentation PMI provides publicly, the patent and that
leaked to the authors. The limitations identified in Codentify
are that, if a code is used twice, the Codentify system cannot
alone determine which of the two products with this code is genuine
or counterfeit. An analysis of the package at the consumer service
centre is required to confirm the authenticity. More generally
the code is visible on the packs, making it easy to read and recognise,
but less secure as visible codes are easier to falsify.[61]
49. The revised EU Tobacco Products Directive, governing
the manufacture, presentation and sale of tobacco and related
products, was formally approved by the European Parliament on
26 February 2014, and was officially adopted by the European Council
on 14 March 2014.[62]
50. The new Directive introduces an EU-wide tracking
and tracing system for the legal supply chain and visible and
invisible security features, such as holograms, to facilitate
law enforcement and help authorities and consumers detect illicit
products.[63]
51. The new Directive specifically allows Member
States to introduce further measures relating to standardisation
of packaging, where they are justified on grounds of public health,
are proportionate and do not lead to hidden barriers to trade
between Member States.[64]
52. The new Directive should enter into force in
May 2014. A transposition period of two years for Member States
to bring national legislation into line with the revised Directive
means that most of the new rules will apply in the first half
of 2016.[65]
53. An effective track and trace system could
potentially mitigate many of the possible risks which have led
the Government to adopt a more cautious approach to standardised
packaging. Any increase in criminality should be avoided at all
costs and considerations on standardised packaging must be taken
on health and commercial grounds. Therefore, we recommend that
any future legislation to introduce standardised packaging should
include a requirement for appropriate security and tracking features,
in accordance with the EU Tobacco Products Directive and best
evidence.
1 HMRC, Tobacco tax gap estimates 2012-2013 Back
2
Sir Cyril Chantler, Standardised packaging of tobacco: Report of the independent review undertaken by Sir Cyril Chantler,
3 April 2014, p. 33 Back
3
European Parliament, answer on behalf of the European Commission,
given by Mt Semeta. Cigarette Smuggling, E-9307/2010, 4 January 2011.
Back
4
Ibid. Back
5
World Customs Organisation, Illicit Trade Report 2012 (Brussels,
2013), p. 20 Back
6
Sir Cyril Chantler, Standardised packaging of tobacco: Report of the independent review undertaken by Sir Cyril Chantler,
3 April 2014, p. 33 Back
7
HMRC, Tackling Tobacco Smuggling-building on our successes, A renewed strategy for HM Revenue and Customs and the UK Border Agency
(2011), para 3.3. See also NAO, Progress in Tackling Tobacco Smuggling,
June 2013, Figure 5, p. 18 Back
8
HMRC, Tackling Tobacco Smuggling-building on our successes, A renewed strategy for HM Revenue and Customs and the UK Border Agency
(2011), p. 1 Back
9
HMRC, Tackling Tobacco Smuggling-building on our successes, A renewed strategy for HM Revenue and Customs and the UK Border Agency
(2011), para 3.7. Raquel and Jin Ling are well established illicit
white brands in the UK. HMRC seized 47 million Jin Ling cigarettes
in the UK in 2010-11 - a quarter of all seizures of illicit whites
in that year. Back
10
HMRC, Tackling Tobacco Smuggling-building on our successes, A renewed strategy for HM Revenue and Customs and the UK Border Agency
(2011), para 1.2 Back
11
HMRC, Tackling Tobacco Smuggling-building on our successes, A renewed strategy for HM Revenue and Customs and the UK Border Agency
(2011) Back
12
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013), p. 24 Back
13
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013) Back
14
Q108 (Jim Harra) Back
15
HMRC, Measuring tax gaps 2013 edition Back
16
HMRC, Tobacco tax gap estimates 2012-13 Back
17
Includes duty and VAT, based on the Weighted Average Price (WAP)
of all UK duty paid cigarettes. Back
18
HMRC, Tobacco tax gap estimates 2012-13 Back
19
Figures are independently rounded to the nearest 1 percent, £100
million or 100 tonnes. Back
20
Includes duty and VAT, based on the Weighted Average Price (WAP)
of all UK duty paid cigarettes. Back
21
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013), para 2.28 Back
22
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013), para 1.20 Back
23
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013), para 4 Back
24
Duncan Robinson, Smokers turning more to illicit tobacco, Financial
Times, 17 April 2013. KPMG, Project Star 2012 Results, 16 April
2013, p. 28. Back
25
For example see on 7 March 2013, Border Force reported that officers
had seized 30 million counterfeit cigarettes in Southampton, which
were being smuggled from China. If the haul had not been intercepted
it would have cost the Treasury approximately £8,064,000
in lost revenue. Back
26
Submission by Border Force, HMRC and National Crime Agency Back
27
There is no direct correlation between arrest and prosecution
numbers as many cases are progressed using information and summons
rather than arrest. Back
28
National Audit Office, NAO analysis of HM Revenue & Customs performance data,
NAO (2013), para 2.40 Back
29
Independent Chief Inspector of Borders and Immigration, An Inspection of Border Force Freight Operations March 2013-July 2013,
pp. 4-5 Back
30
Q 90 (Jim Harra) Back
31
Border Force response to the recommendations of the Independent Chief Inspector of Borders and Immigration: An inspection of Border Force freight operations,
p. 1 Back
32
Q 90 (Jim Harra) Back
33
Submission by Border Force, HMRC and National Crime Agency Back
34
HMRC, Tobacco products duty: control of supply chains Back
35
Q 111 (Jim Harra) Back
36
HM Treasury, Treasury Minutes: Government responses on the Twenty Third to the Twenty Sixth, the Twenty Ninth and Thirtieth Reports from the Committee of Public Accounts (Session 2013-14), and progress on Government Cash Management (2014)
p. 2 Back
37
Q 111 (Jim Harra) Back
38
Q 112 (Jim Harra) Back
39
Submission by Border Force, HMRC and National Crime Agency Back
40
Ibid. Back
41
HM Treasury, Treasury Minutes: Government responses on the Twenty Third to the Twenty Sixth, the Twenty Ninth and Thirtieth Reports from the Committee of Public Accounts (Session 2013-14), and progress on Government Cash Management (2014)
p. 2 Back
42
Tackling tobacco smuggling - Quarter 3 outputs (October to December 2013),
March 2014 Back
43
Standardised packaging (or 'plain packaging') of tobacco products
is generally taken to mean the removal of all attractive promotional
aspects. Except for the brand name (which would be presented in
a standardised way), all other trademarks, logos, colour schemes
and promotional graphics would be prohibited. The package itself
would be standardised and display only information (such as health
warnings) required by law. See Standardised packaging of tobacco products, House of Commons Library Standard Note SN/HA/6175
(March 2014). Back
44
Department of Health, Consultation on standardised packaging of tobacco products: Summary report, July 2013,
p. 22 Back
45
Ibid. Back
46
Department of Health, Consultation on standardised packaging of tobacco products: Summary report, July 2013,
p. 22 Back
47
Submission by Jonathan Isaby, TaxPayers' Alliance Back
48
UK Law Enforcement Views on Illegal Tobacco and Plain Packaging, Populus,
p. 17 Back
49
Submission by Trading Standards Institute Back
50
House of Lords European Union Sub-committee (Home Affairs), July
2013, Q 18 (Nicholas Ilett) Back
51
Australian Government Department of Health, Plain packaging of tobacco products,
31 July 2013 Back
52
Department of Health, Press release: Consultation on standardised packaging of tobacco products,
12 July 2013 Back
53
Sir Cyril Chantler, Standardised packaging of tobacco: Report of the independent review undertaken by Sir Cyril Chantler,
3 April 2014, p. 6 Back
54
Q 102 (Jim Harra) Back
55
Submission by Border Force, HM Revenue and Customs and National Crime Agency,
p. 5 Back
56
Department of Health, Oral statement to Parliament: Chantler report on standardised packaging of tobacco products,
3 April 2014 Back
57
Submission by SICPA UK Back
58
Submission by SICPA UK Back
59
Submission by Tobacco Manufacturers' Association Back
60
Ibid. Back
61
Luk Joossens & Anna B Gilmore, 'The transnational tobacco companies' strategy to promote Codentify, their inadequate tracking and tracing standard',
Journal of Tobacco Control, March 2013 Back
62
European Commission, Revision of the Tobacco Products Directive Back
63
European Commission (Public Health), Questions & Answers: New rules for tobacco products,
26 February 2014 Back
64
Ibid. Back
65
European Commission (Public Health), Questions & Answers: New rules for tobacco products,
26 February 2014 Back
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