HMRC: Vaping Product Manufacturer Approval Changes Demand Timely Updates

• Vaping Products Manufacturer Approval (VPMA) holders must notify HMRC of any changes to their application.
• Notifications are required either before changes occur or within 14 calendar days, with penalties for non-compliance.
• Updates must include altered business details, ownership information, and manufacturing premises or production methods.
• Specific ownership details include individuals with past Customs and Excise Act issues.
• Submissions can be made online via Government Gateway or by post, with HMRC aiming to review within 45 working days.

Timeliness is a critical aspect of this compliance framework.

Holders of Vaping Products Manufacturer Approval (VPMA) are under a strict obligation to inform His Majesty's Revenue and Customs (HMRC) about any alterations to their approved application. This requirement ensures that the regulatory body maintains accurate and up-to-date records of all approved manufacturers operating within the UK. The process for reporting these changes typically involves utilizing a dedicated online form, though alternative submission methods are available for those unable to access digital services.

Timeliness is a critical aspect of this compliance framework. While some modifications necessitate notification to HMRC *before* they are implemented, others must be reported *within 14 calendar days* of their occurrence. Failure to adhere to these precise deadlines, or neglecting to report changes altogether, can lead to the imposition of penalties, underscoring the importance of diligent adherence to these reporting requirements for all vaping product manufacturer approval changes.

When a vaping business undergoes changes, only the specific details that have been altered need to be communicated to HMRC. This includes fundamental business information such as the registered business name, any trading names in use, the official registered address, and primary contact information. Additionally, manufacturers must declare their VAT registration status and provide the corresponding VAT registration number if applicable, ensuring that all vaping business details update HMRC accurately.

Significant changes in ownership also trigger mandatory notification. This encompasses providing details about any individual who holds an ownership stake, exercises control, manages, or is otherwise involved in the operation of the business. Furthermore, it is imperative to disclose information regarding any such individual who has previously faced convictions, penalties, or forfeitures under the Customs and Excise Acts. While these details can be submitted via the designated form, HMRC reserves the right to contact the manufacturer directly for further clarification if necessary, ensuring comprehensive vaping ownership change notification.

Manufacturers must also report alterations related to their production activities and facilities. Similar to business details, only the specific production aspects that have changed require notification. This includes modifications to production methods, adjustments in overall production capacity, and any changes to the types of vaping products being manufactured. These updates are crucial for maintaining Vaping Products Manufacturer Approval compliance.

Should there be changes to manufacturing details, particularly those involving premises, manufacturers may be required to submit a revised business plan. For each affected manufacturing premises, specific information must be provided, including its full address, relevant contact details, and a clear description of the activities conducted at that location. This ensures HMRC has a current understanding of the operational footprint and capabilities, facilitating accurate HMRC vaping manufacturing premises update records.

The primary method for submitting these required changes is through an online portal, necessitating a Government Gateway user ID and password for access. Manufacturers are advised to consolidate all necessary updates into a single form submission. The online system allows users to save their progress, facilitating completion over multiple sessions if required. Upon successful submission, a confirmation email containing a unique submission reference will be dispatched.

For those unable to utilize the online platform, changes can be reported by post by writing directly to HMRC. Following submission, HMRC aims to review and update the application within 45 working days. However, the actual processing time can vary depending on the complexity of the reported changes. It is important to note that the review period may extend beyond 45 days if HMRC needs to request additional information from the manufacturer to fully assess the updates.

This guidance outlines critical compliance obligations for Vaping Products Manufacturer Approval holders in the UK. Lawyers and compliance officers must advise clients on the strict deadlines (before changes or within 14 days) for notifying HMRC of any alterations to business, ownership, or manufacturing details, to mitigate the risk of penalties for non-compliance.

Source: Original reporting via GOV.UK