Tobacco Manufacturing UK-wide

Tobacco manufacturer: compliance checklist

Use this checklist to confirm your tobacco manufacturing business (SIC division 12) meets its obligations before a production run. Work through the universal workplace and employment items every manufacturer shares, then the tobacco-specific product, duty and track-and-trace items. If you answer no to any item, follow the linked guide before you proceed.

Guide summary

Before each production run, work through this checklist to confirm your tobacco factory meets workplace health and safety rules and tobacco-specific product, duty and supply-chain rules. You must have risk assessments, safe machinery, employers' liability insurance (at least £5 million), and approval from HMRC for excise duty. If you answer no to any item, follow the linked guide before you proceed.

  • Write risk assessments and put safe systems in place
  • Control tobacco dust and casing chemicals under COSHH
  • Guard, maintain and inspect machinery under PUWER
  • Assess manual handling and fire risks
  • Hold employers' liability insurance of at least £5 million
  • Meet tobacco product standards and report to MHRA
  • Use standardised plain packaging with correct health warnings
  • Get approved or registered with HMRC for excise duty
  • Apply duty stamps to cigarette and hand-rolling tobacco packs
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Related guides in Health & Safety

Use this checklist to confirm your tobacco manufacturing business meets its obligations before a production run. Work through each item and answer yes or no. If you answer no, follow the linked guide before you proceed.

Workplace health and safety is enforced by the Health and Safety Executive in Great Britain and by HSENI in Northern Ireland. The tobacco product standards, standardised packaging, excise duty and track-and-trace rules apply UK-wide. The residual general product safety duty is a Great Britain regime, so if you supply Northern Ireland, check that position separately under the Windsor Framework. Each section names the body that applies.

Section 1 — Every tobacco manufacturer (factory and people)

These workplace and employment duties apply to every manufacturer, whatever you make. Confirm each one before you start production.

  1. 1

    Have you written your risk assessments and put safe systems of work in place?

    Your general duty under the Health and Safety at Work etc. Act 1974 is to ensure, so far as is reasonably practicable, the health, safety and welfare of your people. Risk-assess conditioning, cutting, drying, making and packing and put safe systems of work, training and supervision in place. If not, follow "Set up and run a safe tobacco factory".

  2. 2

    Have you assessed and controlled exposure to tobacco dust and casing chemicals?

    COSHH requires control of respirable tobacco dust and casing/flavouring substances, with local exhaust ventilation and health surveillance where required.

  3. 3

    Is your machinery safeguarded, maintained and inspected under PUWER?

    Cutting, making and packing machinery must be guarded, maintained and safely isolated for cleaning and unblocking under PUWER.

  4. 4

    Have you assessed manual handling and carried out your fire risk assessment?

    Reduce hazardous handling of leaf, packaging and product. Assess fire risk from dried tobacco and combustible dust under the fire-safety regime for your nation.

  5. 5

    Do you hold employers' liability insurance and meet your equality and data duties?

    Hold at least £5 million of cover once you employ anyone. Do not discriminate under the Equality Act 2010 (or separate NI equality law enforced by the ECNI). Comply with the UK GDPR and Data Protection Act 2018, registering with the ICO unless exempt.

Section 2 — Tobacco product, duty and supply-chain rules

These tobacco-specific obligations apply to the product you make and how it moves through the supply chain. Confirm each one before you place product on the market.

  1. 1

    Do your products meet the tobacco product standards and reporting rules?

    Meet 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. If not, follow "Meet your tobacco product, duty and track-and-trace obligations".

  2. 2

    Is your packaging standardised, with the right health warnings?

    Cigarettes and hand-rolling tobacco must be in the prescribed plain packaging — no branding, the prescribed colour and format — with the required health warnings, enforced by Trading Standards. Other products must still meet the residual general product safety duty (GPSR 2005, OPSS / Trading Standards in GB).

  3. 3

    Are you approved by HMRC for tobacco products duty and applying duty stamps?

    As a manufacturer you must be approved or registered with HMRC, account for excise duty under the Tobacco Products Duty Act 1979, apply duty stamps to cigarette and hand-rolling tobacco packs, and keep the records HMRC's excise controls require. This applies UK-wide.

  4. 4

    Are you registered for tobacco track-and-trace with HMRC?

    Obtain an economic operator identifier (EOID) and a facility identifier (FID) for each premises, apply unique identifiers and the security feature to packs, and record and report product movements to the UK track-and-trace system under the 2019 Regulations. This applies UK-wide.

If you answered no to anything

Work through the guide linked in that item before your production run. The two task guides — the safe-factory spine and tobacco product, duty and track-and-trace obligations — set out what to do. Start from the router if you are not sure which apply to you.

Official sources

Authoritative health and safety, tobacco product and duty guidance.