Beyond running a safe factory, the tobacco product itself is one of the most closely controlled consumer goods in the UK. The rules in this guide cover what the product must be like and how it must be packaged, the duty you must account for, and the system that tracks every pack through the supply chain. They apply in addition to — not instead of — the workplace duties in the safe-factory spine. Several different bodies are involved: the MHRA for product notification, Trading Standards and the Office for Product Safety and Standards (OPSS) for product and packaging standards, and HM Revenue & Customs (HMRC) for duty and track-and-trace.
A. Meet the tobacco product standards and packaging rules
The Tobacco and Related Products Regulations 2016 set the product standards — ingredient and emission limits, maximum tar, nicotine and carbon monoxide yields, annual ingredient and emission reporting, and health-warning and labelling rules. For e-cigarettes and refill containers you must notify the MHRA at least six months before placing a product on the market. On top of that, the Standardised Packaging of Tobacco Products Regulations 2015 require cigarettes and hand-rolling tobacco to be produced in standardised ("plain") packaging — a prescribed drab dark-brown colour, no branding, and a fixed pack format and surface finish. These rules apply UK-wide.
B. Meet the residual general product safety duty
Where no specific product-safety regime applies, the General Product Safety Regulations 2005 set a residual duty to place only safe products on the market. For tobacco, product composition is governed primarily by the tobacco-specific regimes above, so this is a baseline rather than your main obligation. The General Product Safety Regulations 2005 are a Great Britain regime enforced by OPSS and Trading Standards; if you supply the Northern Ireland market, check the position there separately, as Northern Ireland follows EU product-safety rules under the Windsor Framework.
C. Account for tobacco products duty
Tobacco products manufactured in the UK are subject to excise duty under the Tobacco Products Duty Act 1979. As a manufacturer you must be approved or registered with HMRC, account for the duty, and apply duty stamps to cigarette and hand-rolling tobacco packs. The duty point arises when the goods are released for consumption — for a manufacturer, on release from your registered premises — and you must keep records and follow HMRC's excise controls, including the movement-control rules for duty-suspended goods. The duty applies across the United Kingdom and is administered by HMRC.
D. Join the tobacco track-and-trace system
As a manufacturer you are the first economic operator in the tobacco supply chain, so the UK track-and-trace system applies to you directly under the Tobacco Products (Traceability and Security Features) Regulations 2019. You must obtain an economic operator identifier (EOID) and a facility identifier (FID) for each of your premises, apply a unique identifier (UID) to every unit packet and aggregated packaging, apply the required security feature, and record and report the movement of products to the UK track-and-trace system so that packs can be traced through the chain. The system is administered by HMRC and is designed to combat the illicit tobacco trade. It applies across the United Kingdom.
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1. Meet the product standards and report your ingredients
Comply with the ingredient, emission and yield limits in the Tobacco and Related Products Regulations 2016, submit your annual ingredient and emission reporting, and notify the MHRA for any e-cigarette or refill product at least six months before launch.
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2. Produce standardised packaging with the right health warnings
Make cigarettes and hand-rolling tobacco in the prescribed plain packaging, with no branding and the required health warnings and labelling.
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3. Get HMRC approval and account for duty
Register or get approval with HMRC, account for excise duty, apply duty stamps to cigarette and hand-rolling tobacco packs, and keep the records HMRC's excise controls require.
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4. Set up track-and-trace
Obtain your economic operator and facility identifiers through the UK track-and-trace system (administered by HMRC), apply unique identifiers and the security feature to packs, and record and report product movements to the system.
What to do next
With your safe-factory spine and these tobacco-specific obligations in place, confirm the whole picture holds together with the tobacco manufacturer compliance checklist. If you are not sure which guides apply to you, start from the router.
Official sources
Authoritative tobacco product, duty and track-and-trace guidance.