HMDS2938 - Record keeping requirements: Records to be kept for stamped goods held or moved
Regulation 27 requires that all traders in the supply chain who hold or move stamped product must identify that those goods are stamped in their ordinary business records. This applies to product bearing both Type A and Type B stamps. However, this requirement only affects traders who are not otherwise obliged to keep records under Regulations 25 or 26. For example, where a warehousekeeper affixes Type A stamps to a consignment of spirits, and so is obliged to meet the requirement to identify stamped stock under the provisions of Regulation 25(g), he will therefore not have to do anything further under Regulation 27. However, if he affixes labels that include a Type B stamp, or he receives goods that have been stamped elsewhere into the warehouse, he must identify those goods as being stamped within his business records under Regulation 27.
The requirement under Regulation 27 to identify stamped bottles of spirits in business records also applies to wholesalers and retailers.
Similarly, in Northern Ireland only, where Registered Consignees affix Type A stamps, they are required to keep the records specified in Regulation 25, and therefore Regulation 27 doesn’t apply. But if they receive product that is already stamped, they must identify the stamped bottles of spirits in their records.
It is up to each individual trader to decide what arrangements they want to make in order to meet this requirement - they may wish to introduce new stock-keeping units and/or consider somehow marking pallets to make it easier for them to identify stamped stock.
Where duty stamped goods are moved in duty suspense within the UK the W8 form must bear a statement in Box 18A or 25 showing that the goods are stamped.