The changes to the guidelines should be seen in the light of the original text 
being very OSMish, trying to leave some wiggle room and trying not to come over 
as an absolute law, but I believe the intention was always that seperate 
accounts would be the norm.

In reality a large number of importers ignored (not only) the provision in 
question and resorted to mincing words to justify it (Mike being a good example 
of this). The clarification should be seen as a step to avoid that.

The licence change process in particular turned up a large number of 
(problematic and others) imports where the importers washed their hands of 
their responsibility and left the clean up work to others.

Simon

-- 
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