The Trading Standards Joint Advisory Board for Brent and Harrow met on Wednesday 5 November 2025 to review mid-year performance and discuss Operation CeCe, an initiative to tackle illegal tobacco. The Board noted the significant progress made in both areas, including a substantial number of enforcement visits and seizures of illicit products.

Trading Standards Mid-Year Review

Anu Prashar, Senior Regulatory Service Manager for Trading Standards, presented the mid-year review, highlighting the service's performance and achievements. A key development mentioned was the introduction of new legislation: the Digital Markets, Competition and Consumers Act 2024, which replaces the Consumer Protection from Unfair Trading Regulations 2008, and the Environmental Protection (Single-use Vapes) (England) Regulations 2024, banning the sale of single-use vapes.

The service received 2,116 service requests, with 960 further analysed. Of these, 512 related to Brent and 448 to Harrow. Businesses also made 70 requests for advice. A total of 120 enforcement visits were conducted to ensure businesses comply with the law. Underage test purchase operations, involving products such as vapes, alcohol, and cigarettes, saw 38 businesses tested, with a 15% failure rate. The report also detailed the seizure of illicit tobacco, with 22 businesses visited for compliance checks. High-risk businesses, identified through previous prosecutions or dealing with high-risk products, were also inspected, with 27 visited so far this year.

The service operates on an intelligence-led approach, gathering information from the public, businesses, and other agencies. Partnerships with the police and HMRC are crucial for sharing intelligence. Underage test purchases were conducted on 38 businesses, with a 15% failure rate, including five vape sales and one butane sale.

The report noted 16 infringement reports, with 14 resulting in warning letters. Four cases proceeded to legal proceedings, concluding with six defendants and £3,132 in costs awarded. Five final notices were issued to letting agents for failing to comply with the Consumer Rights Act and client money protection regulations, resulting in monetary penalties of nearly £13,000. The council's two financial investigators have secured £193,376 in confiscation orders under the Proceeds of Crime Act.

Councillor Daniel Kennelly asked about the intelligence gathering process and how to counter businesses warning each other of enforcement visits. Anu Prashar explained that while direct prevention of such warnings is difficult, the use of sniffer dogs can help locate hidden illicit products. Councillor Kennelly also inquired about the timeline for implementing closure orders for illicit tobacco shops, with Anu Prashar stating that templates are in place and the process is being explored, particularly for repeat offenders.

Councillor Norman Stevenson sought clarification on the service request figures, and Anu Prashar explained that the 960 analysed requests are prioritised. Councillor Krishna Suresh asked about any increase in specific offences compared to the previous year, and Anu Prashar noted that while overall offences haven't increased, illicit tobacco remains a significant issue. The discussion also touched upon the issue of pawn spitting (likely referring to e-cigarette vaping devices), with Emma Faisi, Strategic Head of Public Protection and Enforcement, explaining that once made up, these can be treated as food products, and environmental health teams would handle non-tobacco related issues.

The Board noted the report, with Councillor Pritesh Patel requesting more explicit timeframes for the reporting periods in future.

Operation CeCe - Joint Advisory Board Report

Samuel Abdullahi, Brent and Harrow Trading Standards Team Leader, presented the update on Operation CeCe, a national initiative in partnership with HMRC to combat illegal tobacco. The operation, which began in January 2021, aims to disrupt the sale and supply of illicit tobacco products across England and Wales. The funding provided by HMRC to National Trading Standards is then allocated to local authorities like Brent and Harrow.

The report outlined the relevant legislation, including the Standardised Packaging of Tobacco Products Regulations 2015 and the Tobacco and Related Products Regulations 2016, which mandate plain packaging and specific health warnings. Selling non-compliant products is a criminal offence, with potential for seizure of goods and prosecution.

Operation CeCe focuses on disruption work, including test purchasing and enforcement visits using sniffer dogs. Between March 2021 and September 2025, Brent and Harrow Trading Standards conducted 184 enforcement visits, seizing over 480,580 sticks of illegal cigarettes, 10kg of hand-rolling tobacco, 23kg of smokeless tobacco, and 115kg of shisha products. Sixty-three letters of warning and 10 simple cautions were issued. Twenty-four cases have concluded in court, resulting in fines totalling over £38,000 and £25,000 in costs awarded to the service. The cost recovery for officer time from Operation CeCe since March 2021 amounts to £25,841.

Councillor Daniel Kennelly questioned why the Operation CeCe funding cannot be used for underage test purchasing, and Samuel Abdullahi explained that the funding is ring-fenced specifically for illicit tobacco disruption. He also confirmed that online purchases have not yet been monitored but suggested it as a future consideration. Councillor Kennelly also enquired about the disparity in enforcement visits between Brent and Harrow, which Samuel Abdullahi attributed to the number of complaints received.

Councillor Norman Stevenson asked for clarification on the letters of warning issued for infringements. Samuel Abdullahi explained that these are typically issued for small quantities of illicit tobacco or when circumstances warrant a less severe initial action, with escalation to cautions or prosecution for repeat offences or larger seizures. He highlighted a case where a shop owner was prosecuted five times, eventually receiving an immediate custodial sentence, demonstrating the council's commitment to taking strong action.

The Board noted the report and thanked the officers for their work. The next meeting is scheduled for Thursday, 5 March 2026.