What are the current HMRC duty stamp placement requirements and compliance issues that retailers are enforcing?

Members report that **Master of Malt (MOM)** has become notably strict on duty stamp compliance following an HMRC inspection several years ago. Key issues they're enforcing:

- **Stamp placement touching labels**: MOM's compliance team is rejecting bottles where the duty stamp merely touches or overlaps with the label, even if placement is technically within HMRC regulations. - **Labels on wrapped bottles**: MOM rejected maraschino bottles wrapped in straw where the label wasn't applied directly to the glass bottle itself, despite this being permitted under legislation (straw is deemed part of the bottle assembly).

Members note that while duty stamps were originally introduced to prevent duty drawback fraud, there's scepticism about their effectiveness—some heard rumours that HMRC has accepted the scams they were meant to eradicate have largely disappeared and may be considering phasing stamps out altogether. The **BDA (British Distillers Association)** is reportedly campaigning to get stamps removed entirely.

Caveat: Members expressed frustration that no one appears to have actually been prosecuted for duty stamp errors, questioning whether the compliance burden genuinely prevents fraud. MOM's strict approach appears to be self-imposed rather than mandated by HMRC itself, though it stems from their past inspection experience.