Another system of denaturing involves ‘in-line’
blending. Using this method, alcohol, markers and denaturants are
released from separate holding tanks for mixing (denaturing) in the
pipework of the plant before being received into a road tank wagon.
This system enables the producer to produce denatured alcohol to
order, thus eliminating the need to hold bulk stocks of various
denatured alcohol formulations. This system has obvious advantages
for the producer, but you should fully consider and address the
risks to the revenue inherent in the trader’s proposed system
before giving approval.
In particular, you must be satisfied that the denatured
alcohols produced will meet the standards set out in
Notice 473: Production, Distribution and Use
of Denatured Alcohol. The producer should be required to provide
an adequate level of assurance by either sampling every batch of
denatured alcohol produced or have in place a satisfactory
verification system (e.g. a pre-mixed and tested marker and
denaturant concentrate which can provide assurance of denaturing
adequacy by monitoring the denaturant content of the final
product).
The producer must be made aware that under-denatured alcohol
remain’s liable to duty at the rate appropriate to the type
of alcohol used and that it is therefore in the producer’s
own interests to ensure that the correct standards are maintained.
If you need assistance when considering applications for
‘in-line’ denaturing operations, contact the Alcohol
Team, Ralli Quays who will be pleased to offer further advice.
