Record keeping and returns

Manufacturers and importers, distributors and retailers of regulated products must keep sales records and provide annual reports and returns to the Vaping Regulatory Authority. The reports and returns will be due with the Authority by 31 January each year for the previous calendar year.

Record-keeping requirements

Manufacturers, importers, exporters, distributors and retailers of regulated products (smoked tobacco, vaping, herbal smoking and smokeless tobacco products) are responsible for keeping accurate records for all of their regulated products.

Manufacturers, importers, exporters, distributors, and retailers of a regulated product must take reasonable steps to keep accurate records of:

  1. all the regulated products that they manufacture, import, export, buy, sell, or supply; and
  2. for a manufacturer, the constituents required by regulations to be recorded that the manufacturer uses or intends to use in the manufacture of each regulated product.

Our expectation is that a manufacturer/importer/exporter will already be keeping accurate records as part of their normal business practice. There is no particular format that businesses must use for their records – it will depend on each business’s management systems.

Records must be kept for 3 years from the date of each transaction. An enforcement officer may require a person to provide a copy of the records kept under this section by notice in writing. The person must provide the enforcement officer with a copy of the records, in the format required in the notice, within 10 working days of receiving the notice.

The enforcement officer will stipulate in the notice whether the records should be provided in paper or electronic format, and how they should be delivered. Only existing records in their existing format will need to be provided.

The Act does not specify exactly what records must be kept but our expectation is that records would include:

  • What products they have purchased, who they purchased them from and when
  • What products they have sold and when
  • Purchase and sale prices
  • Who they sold products to and when
  • Batch/serial numbers of products bought and sold.

In addition, for manufacturers

  • Constituents used or intended to be used in the manufacture of each regulated product
  • What constituents they have purchased, who they purchased them from and when
  • Batch/serial numbers of constituents bought and sold.

Annual Sales Return Template

Please use this template for your annual sales return for the year ending 2022. If you are a Specialist Vape Retailer you must submit one return in CSV format per AVP and one return in CSV format per AIS (if applicable). If you are a Notifier you must submit one return in CSV format. Please upload the annual return by the 31 January 2023 through your HARP portal by selecting the application “VRA Annual Return SVR” or “VRA Annual Return Notifiable Products” as applicable. Please note that UPC is not mandatory in the annual return however if the UPC of the product is known then this should be provided.

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