The Association of Convenience Stores has responded to HM Revenue and Customs’ consultation on alcohol fraud, calling for the regulation of wholesalers to be properly enforced while minimising burdens on retailers.

In its’ response, ACS has called on HMRC to ensure that retailers who very occasionally sell in large amounts do not end up being registered as wholesalers, and that retailers’ requirements to check the legitimacy of their wholesaler are not excessive or burdensome.

ACS chief executive James Lowman said: “Duty fraud is a significant threat to retailers and we welcome HMRC’s proposals to strengthen anti-fraud measures including the registration scheme for wholesalers. However, this must not impose unnecessary burdens on legitimate retailers and therefore propose the following measures to be included in the scheme.

“Retailers who engage in ‘incidental’ wholesaling such as providing a case of alcohol for a local event, or for another business because they have run out, should not be subject to registration. These businesses do not pose a significant duty fraud risk and should not be burdened by registration requirements.

“We strongly oppose any requirement for retailers to undertake and record proactive checks of the registration status of their regular wholesalers. This would impose an unrealistic and overly prescriptive burden on retail customers.”

ACS has submitted evidence that shows that a requirement on retailers to undertake a monthly check of the validity of the registration of their wholesale suppliers would lead to a regulatory burden costing more than £8m. ACS said HMRC has provided reassurances that it is listening to ACS concerns on this point.

James Lowman continued: “We welcome the constructive on-going dialogue we have with HMRC on this issue and are confident they are listening to our concerns. We are committed to find ways to develop a workable system that does not impose unnecessary burdens on legitimate retailers and wholesalers.”